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Cosmetic Labeling Requirements: USA vs EU

July 12, 2019

The beauty industry is experiencing record growth. By 2024, the global cosmetic products market is predicted to reach $863 billion. With so much consumer demand, there are new cosmetic products arriving on store shelves on a near constant basis. And while many shoppers consider themselves to be informed, as 85% of consumers say product packaging influencers their purchasing decisions, they may not be totally cognizant of the finer details that appear as part of cosmetic product branding.

There are specific details that need to be included on custom labeling for cosmetic products within the United States. But these details can differ greatly from the information featured on product labeling for cosmetics within the European Union. If you're a manufacturer who plans on getting your products into international markets and want to gain a more complete understanding of the differences in packaging and labeling requirements on different continents, this post can serve as a helpful starting point.

American Cosmetic Labeling Requirements

In the U.S., the Food and Drug Administration (FDA) controls the regulation of cosmetics products. The 2010 Safe Cosmetics Act was proposed to give this agency the power to control the chemicals used in cosmetics, as well as the potential to ban certain ingredients (like carcinogens and endocrine disruptors). Unfortunately, the bill never made it out of committee. The Fair Packaging and Labeling Act also ensures that consumers obtain accurate information about the contents of the products they buy. The FDA can evaluate the safety of a given cosmetic product and provides guidelines for the unique labels used for cosmetic products. Cosmetic manufacturers must adhere to these guidelines to ensure compliance with their custom labeling.

Typically, cosmetics distributed within the United States need to have two parts included in their custom labeling: the Principal Display Panel and the Information Panel. The PDP is the part of the label that's most likely to be examined by a customer or displayed in a store. It contains the name of the product, how it's used (known as the identity statement), the net quantity (usually the weight or measure of the product included), and any pertinent warning statements. An IP will often include contact information for the manufacturer or distributor, cautionary symbols, a declaration and listing of ingredients, and material facts. All information must be written in English and in a legible type size. Cosmetic labeling needs to be accurate and contain all necessary information to ensure the FDA will not consider a product to be misleading or misbranded.

European Union Cosmetic Labeling Requirements

The EU is comprised of 31 countries in Europe, all of which have come together to regulate products. In many respects, the EU places stricter regulations on the ingredients contained in all kinds of products than what you'll find in the United States. In 2013, the EU Cosmetic Regulation sought out to increase levels of transparency for finished cosmetic products, improve consumer safety, and prevent the use of hazardous substances.

Part of the EU's labeling and production regulations for cosmetics include establishing a Responsible Person (who acts as a representative for your product throughout the European Union); preparing a Product Information File (PIF) that includes a safety assessment; respecting cosmetic Good Manufacturing Practices (GMP); complying with all packaging and labeling requirements; and ensuring notifications through the Cosmetic Products Notification Portal (CPNP).

Cosmetic products in the EU need to contain specific information on their custom labeling. The name and address of the established RP needs to be included, as will the product's function, the nominal content, the batch number, the list of ingredients, and any precautions for use. Aside from product identification information, the date of minimum durability and the period after opening must be included, which tell the consumer about the product's shelf life and overall stability. If the product is made outside of Europe, labels also need to include the country of origin. All writing needs to be legible and easy to understand, while the product function and precautions for use sections need to be translated into the native language of each country in which the product will be distributed.

It's not always easy to gain a thorough understanding of labeling requirements within your own country -- much less an entirely separate continent. If you plan on launching cosmetic products in a new market, you'll need expert assistance to ensure your labels are compliant and enticing.

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