Labeling & Claims
Mandatory, voluntary, and permitted claims for your cosmetic products
Mandatory labeling of cosmetic products
In the EU, mandatory cosmetic labeling includes the written listing of all ingredients with International Nomenclature of Cosmetic Ingredients (INCI) designation, the name of the company and the address of the responsible person, country of origin of the cosmetic imported into the European Union, nominal content, best-before date or shelf life after opening, special precautions, batch number, and intended use of the product. Cosmetics legislation in the EU stipulates that all ingredients of a cosmetic product must be listed in a specific order: according to their percentage by weight in decreasing order. The greater portion a substance occupies, the higher it is listed in the ingredients. This applies to all ingredients that individually make up more than 1 percent of the contents. Exceptions include, for example, ingredients from nanomaterials. These must all be explicitly named. Other special cases are regulated in the EU Cosmetics Regulation.
Cosmetics marketed in the United States, whether manufactured here or imported from abroad, must be in compliance with the provisions of the Federal Food, Drug, and Cosmetic Act (FD&C Act), Fair Packaging and Labeling Act (FP&L Act), and the regulations published under the authority of these laws. The regulations related to cosmetics are stated at 21 CFR, parts 700 to 740. The color additive regulations that apply to cosmetics are found at 21 CFR 73, 74, 81 and 82.
Voluntary claims of cosmetics
Voluntary claims of cosmetics are permissible to further inform the consumer or to promote the product (e.g., indicating on the packaging: “without animal testing”).
Advertising statements (claims) of cosmetics
The EU requirements for advertising claims for cosmetics (e.g. smoother and wrinkle-free skin after three weeks of use) are based on the EU Cosmetics Regulation. Depending on the European country e.g. for Germany additional national law applies: Sections 26 to 29 of the German Food, Commodities and Feed Code (Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch, LFGB), Regulation (EU) No. 655/2013, the Unfair Competition Act (Gesetz gegen unlauteren Wettbewerb, UWG) and the German Drug Advertising Act (Heilmittelwerbegesetz, HWG) apply.
We manage legally compliant labeling for you and make proposals for the advertising claims of your cosmetic products. Feel free to contact us!