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EU Cosmetic Label Compliance Checklist

The definitive 32-point checklist for EU Regulation 1223/2009 compliance. Tick off each item to make sure your cosmetic product label is ready for the European market.

Interactive checklistUpdated March 2026Copy & share anywhere

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Mandatory Label Information

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Art. 19, Reg (EC) 1223/2009

Product name / function clearly statedMust be unambiguous to the consumer (e.g. "hand cream", "shampoo"). If the function is not obvious from the name, it must be stated separately.

Responsible Person: name + full EU postal addressFull postal address required. Post-Brexit: a UK address is no longer valid for EU market

Country of origin (if manufactured outside EU)Required for non-EU manufactured products — "Made in [country]"

Net content in metric units (ml/g)Include the estimated quantity "e" mark for pre-packed products >5g/5ml

Batch number / lot code on container and outer packagingMust be present for traceability. Fines up to €90,000 in some member states

PAO symbol (Period After Opening) or BBD (Best Before Date)BBD required if shelf life <30 months; PAO symbol (open jar icon, e.g. 12M) if shelf life >30 months

List of ingredients preceded by the word "Ingredients"Must use the exact heading "Ingredients" — no variations like "Contents" or "Composition"

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INCI Ingredient List

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INCI Nomenclature / Annex II–VI

All ingredients use correct INCI nomenclatureUse standardised names — e.g. "Tocopherol" not "Vitamin E", "Aqua" not "Water"

Listed in descending order of concentrationBy weight at the time of incorporation into the formulation

Ingredients under 1% listed in any order after the 1% cutoffCommon practice: ingredients ≥1% in strict descending order, then <1% in any order

Colorants listed using CI (Colour Index) numbersUse format "CI 77891" not "Titanium Dioxide" in the ingredients list

Nanomaterials identified with [nano] suffixe.g. "Titanium Dioxide [nano]" — required since July 2013 per Art. 19(1)(g)

Fragrances listed as "Parfum" or "Aroma" (plus individual allergens)Fragrance compositions can be grouped but allergens above thresholds must be named individually

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Allergen Declarations

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Annex III, Reg (EC) 1223/2009

All 80+ EU-listed fragrance allergens checked against thresholdsIncludes Linalool, Limonene, Citronellol, Geraniol, Coumarin, Eugenol, Citral, Benzyl Alcohol, and 50+ others added by Regulation 2023/1545

Leave-on products: allergens declared if >0.001% (10 ppm)Lower threshold because of prolonged skin contact

Rinse-off products: allergens declared if >0.01% (100 ppm)Higher threshold due to shorter contact time with skin

Each allergen listed individually — not hidden under "Parfum"Each allergen above threshold must appear as a separate entry in the ingredients list

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Warnings & Precautions for Use

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Art. 19(1)(f), Reg (EC) 1223/2009

All mandatory warnings and precautions includedProduct-specific warnings per Annexes III–VI (e.g. "Avoid contact with eyes", sunscreen SPF warnings, hair dye allergy warnings, aerosol safety)

Precautions displayed legibly on the productMust be clearly readable by the consumer at point of sale

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Claims Compliance

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Reg (EC) 655/2013

No medicinal or therapeutic claims on label"Cures eczema", "treats acne", "heals wounds" = medicinal claim → product reclassified as medicine

All marketing claims are truthful and substantiatedMust meet the six common criteria: legal compliance, truthfulness, evidential support, honesty, fairness, informed decision-making

"Free from" claims not used for already-banned substancese.g. "paraben-free" is discouraged if parabens are banned in that product category

No claims that denigrate competitorsClaims must not unfairly disparage legally compliant ingredients or products

"Hypoallergenic", "dermatologically tested" etc. backed by evidenceRequires documented testing or studies per (EC) 655/2013 Art. 3

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Language Requirements

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Art. 19(5), Reg (EC) 1223/2009

Mandatory info in official language(s) of each target market countryMost member states require their own official language(s) — English alone is rarely sufficient

Multi-language markets covered (e.g. Belgium: FR + NL + DE)Belgium requires all three official languages. Finland: Finnish + Swedish. Check each target country.

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Recycling & Packaging Symbols

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EU Packaging Directive / National Law

Recycling / packaging symbols included where requiredFrance: Triman logo + Info-tri sorting instructions (mandatory since Jan 2022). Italy: material identification codes. Germany: Green Dot if applicable.

PAO or hourglass symbol correctly formattedUse standardised EU symbols per ISO 11609 / EU cosmetics guidelines

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CPNP Notification & Pre-Launch

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Art. 13 & Art. 11, Reg (EC) 1223/2009

CPNP notification filed before placing product on EU marketSubmit via the Cosmetic Product Notification Portal at least 24h before launch

Product Information File (PIF) complete and accessibleMust be kept at the RP address and available to authorities for 10 years after last batch

Cosmetic Product Safety Report (CPSR) documentedPart A (safety data) + Part B (safety assessment by qualified assessor) must be complete

Label reviewed against latest regulation updatesEU regulations are updated regularly — verify against the most current consolidated text

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