What Are The Requirements For Product Labels? (Using the Netherlands as an example)
This time, let's talk about cosmetic label compliance. It might not seem like a complex issue, but often, due to brand owners' lack of attention, non-compliance can create serious obstacles for the subsequent distribution of products. In this edition, we continue to use the Netherlands as our entry point to explore the regulatory and practical aspects to consider when bringing products to the EU market.

What are the legal requirements for cosmetic labels?

Article 19 of the EU Cosmetics Regulation No 1223/2009 provides detailed stipulations for product labeling. It mainly lists the information that must be present on the label, and this information must be indelible, easily legible, and visible. The Dutch Cosmetics Decree has also established detailed implementation guidelines under the EU regulation.

The information that must be listed on the label includes (using the Netherlands as a reference):

1. Responsible Person Information (Name and Registered Address): This is the confirmation of the Responsible Person (RP) identity that we have previously emphasized, and it must be an entity within the EU. This address must be contactable, as regulatory authorities may contact the RP at any time, either in person or by letter, to conduct spot checks on product information.
2. Country of Origin: If the product is imported into the EU from outside the EU, the country of origin must be clearly stated.
3. Product Content Information: Indicate the quantity of items contained in the packaging, using the appropriate unit (weight/volume/pieces) based on the product's characteristics; for example, 50 ml / 100 g / 10 pcs.
4. Expiration Date: The date of minimum durability "ten minste houdbaar tot XXX" must be indicated. However, if the shelf life exceeds 30 months, the Period After Opening (PAO) must be used instead, e.g., 12M + the open jar symbol.
5. Precautions: If the product involves specific precautions stipulated in Annexes III to VI of the EU regulation, these must be stated. For example, if the product is not suitable for infants or should not be used on damaged skin. Additionally, the best method of use for the product must also be indicated.
6. Batch Number or Code: This allows for batch tracing in case product issues arise.
7. Product Function: If the product's appearance is confusing and its purpose is unclear, its function must be stated.
8. Ingredients: Ingredients contained in the product must be listed using the International Nomenclature Cosmetic Ingredients (INCI). It is particularly important to note that the EU has very strict regulations on nanomaterials. All ingredients present as nanomaterials must be listed separately, for example, "zinc oxide (nano)". Ingredients are listed in descending order of weight.

Language Requirements

Some brand owners have a misconception when reviewing labels, believing that English is an international language and therefore using English cannot go wrong. This is a very common pitfall for companies in the EU.
Firstly, the EU regulation delegates labeling requirements to individual EU member states to decide. Therefore, brand owners need to check the specific requirements of the country where the product is sold. For example, in the Netherlands, at least the following information must be presented in Dutch:
. Product function
. Instructions for use
. Any warnings or special precautions
. Content
. Expiration date

The above content is a summary based on laws, regulations, and official information and is for reference only. If you wish to discuss further regarding cosmetics entering the EU market, please feel free to contact the editor via private message.

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