EU Cosmetic Labeling Requirements: A Practical Checklist

Short Answer

For a cosmetic product made available on the EU market, Article 19 of Regulation (EC) No 1223/2009 is the starting point for the consumer-facing label. The final artwork still needs to be checked against the product facts, the Member States where it will be sold and any product-specific rules.

Article 19 Label Checklist

The container and packaging must show the required particulars in indelible, easily legible and visible lettering, subject to the specific exceptions and display rules in Article 19. [20]

• Responsible person: name or registered name and address; if several addresses appear, highlight the address where the PIF is readily accessible. Imported products also identify their country of origin.
• Nominal content at packaging: weight or volume, subject to the stated exceptions for small packs, free samples, single-application packs and certain multipacks.
• Durability: for products with minimum durability up to 30 months, show the date and any storage conditions needed. For products over 30 months, show the period after opening unless that concept is not relevant.
• Use precautions, the batch or reference used to identify the product, and the product function unless it is clear from presentation.
• Ingredients: use the common ingredient names and check the declaration order, colorant rules, nanomaterial marking and other applicable Annex requirements against the current formula.

Check Language by Member State

Article 19(5) leaves the language requirements for specified label information to the law of the Member State where the product is made available to the end user. [20]

A label prepared for one EU country should not automatically be treated as ready for every EU market. Confirm the required language for each target country and for any information provided under the limited Article 19(2)–(4) provisions.

Review Claims Alongside the Label

Regulation (EU) No 655/2013 applies to explicit and implied claims conveyed through text, names, trademarks, pictures and other signs. Claims must meet the common criteria and remain consistent with the documentation supporting the claimed effect in the PIF. [21]

• Do not imply that a cosmetic product has been authorised or approved by an EU authority.
• Keep ingredient claims truthful and supported; the ingredient property alone does not prove the same effect for the finished product.
• Match the strength and wording of each performance claim to adequate, verifiable evidence for the product.
• Check the entire consumer-facing presentation, including images, symbols, product names and online copy used to market the product.

A Practical Review Workflow

• Fix the product identity, formula version, responsible person and EU countries in scope.
• Compare the container, outer packaging, inserts and online presentation as one artwork set.
• Check every Article 19 item and record any exception with its legal basis and display method.
• Match the ingredient declaration to the controlled formula and applicable ingredient-name and Annex rules.
• Review warnings and claim wording against product use, safety information and supporting evidence in the PIF.
• Confirm Member State language requirements and document the approved translation for each market.
• Record the source version, reviewer, product version and changes that trigger another review.

Scope and Review Boundary

This guide covers the EU cosmetics framework. Great Britain and other markets have separate rules and should be reviewed against their own official sources. A general checklist cannot determine whether a particular product, claim or warning is compliant without the product evidence and final artwork.