Table of contents
Introduction to Cosmetic Product Labelling
All cosmetic products, regardless of their form or use, must be properly labelled. Information on the label must be legible, durable, understandable to the consumer, and compliant with applicable laws.
Legal Requirements for Labelling
The legal basis for cosmetic product labelling includes:
- Regulation (EC) No 1223/2009 on cosmetic products,
- Polish Act of 4 October 2018 on cosmetic products (Journal of Laws 2018, item 2227),
- Commission Regulation (EU) No 655/2013 laying down common criteria for claims used in relation to cosmetic products.
Mandatory label elements include:
- product name and function,
- responsible person’s details,
- country of origin (if outside the EU),
- nominal content,
- expiry date (or PAO symbol),
- storage conditions,
- precautions for use,
- batch number or identification code,
- list of ingredients (INCI).
Importance of Marketing Claims
Marketing claims (e.g., “hypoallergenic”, “dermatologically tested”, “natural”, “eco”) must be truthful and supported by appropriate evidence. Misleading claims may constitute a breach of consumer protection regulations.
According to Regulation 655/2013, each claim must be:
- truthful and substantiated,
- supported by evidence (application, dermatological, or lab testing),
- clear, understandable, and relevant to the product’s purpose,
- fair towards competitors,
- allowing consumers to make informed choices.
Common Mistakes in Labelling and Claims
- Using “free from…” claims without justification or legal relevance,
- Highlighting features already required by law (e.g., “not tested on animals” in the EU),
- Lack of mandatory information in the local language of distribution,
- Incorrect order of ingredients in the INCI list,
- Using names or imagery suggesting therapeutic effects.
GCB Services for Labelling Verification
GCB, as an independent notified body, offers services for verifying the compliance of cosmetic product labels and marketing claims with EU legal requirements. The verification includes an assessment of label components, completeness of required information, and evaluation of claims according to Regulation 655/2013. The result is a report summarising compliance status and identifying any non-conformities.
