Cosmetics labelling: what is legally required on the pack

Every week a cosmetics brand arrives at the studio with the container already chosen, the formula ready and a label that does not fit. The right order is the opposite: first you find out what information is mandatory and how much room it takes, then you design.

The reference text is Regulation (EC) 1223/2009 on cosmetic products, which applies across the European Union. It is the rule that decides a good part of your pack before you decide anything.

The mandatory statements, one by one

• Responsible person. Name and address of the natural or legal person established in the EU who answers for the product. It is not necessarily the manufacturer or the brand: it can be a contracted third party.
• Country of origin if the product is imported from outside the Union.
• Nominal content by weight or volume at the time of packaging.
• Minimum durability with the hourglass symbol or the corresponding wording, or the PAO (the open jar with the number of months) when durability unopened exceeds 30 months.
• Particular precautions for use, including those the regulation imposes on specific ingredients.
• Batch number or a reference allowing identification.
• Function of the product, unless it is clear from the presentation.
• Ingredient list preceded by the word Ingredients, in INCI nomenclature.

Where each item can go

The information must appear on the container and on the packaging. In other words: if your cream sits in a jar inside a carton, both carry information, not just the outer one.

When the pack is too small, the ingredient list and the precautions can move to a leaflet, an attached label, a band or a tag. In that case the pack must carry the open book and hand symbol pointing to that information. Without the symbol, the solution is not valid.

Which language

Statements affecting safety and consumer understanding must appear in the language determined by each member state where the product is sold. If you sell in Spain, France and Portugal, those statements multiply, and that is where many packs run out of room.

The INCI list is the exception: it is international nomenclature and is never translated. Neither is the brand name.

How this affects the design

From the first sketch, set aside a service area on the back or the side. The method we use in the studio is simple and prevents almost every problem: lay out the legal block at actual size first, print it, check it reads at thirty centimetres, and design the front with the space that is left.

When the legal block turns up at the end of the process there are only three ways out, and all three are bad: shrink the type below legibility, invade the main face, or reprint.

Mistakes we see again and again

• Legal copy less than three millimetres from the cut, lost in die-cutting.
• Light grey on white in the ingredient list: compliant on paper, unreadable in the hand.
• Batch printed with equipment nobody accounted for in the artwork, covering other information.
• Translations added after the design is closed, with no space planned for them.

A common case: the three-product line

A brand launches three creams sharing a base with different actives. The temptation is to lay out each back separately. The usual result is three different layouts that never align, which multiplies errors and makes templates useless.

The alternative is a master back with fixed zones: ingredients, symbols, batch and date, responsible person. All three references share the structure and only one zone changes. It saves time on every later launch and gives the range coherence on shelf.

Frequently asked questions

Can the ingredient list live on the carton instead of the jar?

Only if the jar is always sold inside the carton and the conditions for small containers are met. If the jar can be sold on its own, it needs its own information.

Can I put the INCI behind a QR code?

Mandatory information must be available on the pack or on the attached support the regulation allows. A QR can complement it, never replace what the rule requires physically.

Who is liable if the label is wrong?

The responsible person for the product. The design studio lays out what that figure validates, which is why it is worth having that sign-off in writing before going to print.

This guide is orientative and does not replace advice from a regulatory specialist. In the studio we design packaging with the legal block built in from the start, not patched on at the end. You can look at success stories or tell us about your project.