Transparency

Our Review Methodology

Exactly which EU regulations we check, what our AI can and cannot determine from a label image, and how you should use your compliance report.

Regulatory Framework

Which regulations we check

Every LabelCheck audit evaluates your cosmetic label against the full scope of EU regulatory requirements. Here are the core frameworks our AI is trained on.

EC 1223/2009

EU Cosmetics Regulation

The primary regulation governing cosmetic products in the European Union. Covers all mandatory labelling requirements.

What we check

  • Responsible Person name and address
  • INCI ingredient list (nomenclature and order)
  • Net content declaration
  • PAO symbol or best-before date
  • Batch / lot code
  • Product function (if not obvious)
  • Language requirements per target market
  • Warnings and precautions
EC 655/2013

Claims Regulation

Sets common criteria for cosmetic product claims. Prohibits misleading, unsubstantiated, or unfair marketing statements on labels.

What we check

  • No prohibited absolute claims
  • Claims consistency with product function
  • Fair and evidence-based language
  • No denigration of competitors
  • No confusion with medicinal products
2023/1545

Expanded Allergen Regulation

Amends Annex III of EC 1223/2009, expanding the mandatory fragrance allergen list from 26 to 80+ substances.

What we check

  • All 80+ listed allergens checked against INCI
  • Threshold verification (10 ppm leave-on, 100 ppm rinse-off)
  • Proper INCI naming for each allergen
  • Cross-reference with fragrance compositions
CLP

Classification, Labelling & Packaging

EU regulation on hazard communication. Applies when cosmetic ingredients require additional safety labelling.

What we check

  • Hazard pictograms where required
  • Signal words for applicable products
  • Precautionary statements
  • Flammability warnings (aerosols, alcohol-based)

Country-specific rules we also check

FranceANSM

Triman symbol, AGEC recycling marks, French language

GermanyBVL

German language, specific labelling format requirements

ItalyISS

Italian language, country-specific precautionary labelling

SpainAEMPS

Spanish language, local registration requirements

AI Capabilities

What our AI can and cannot do

Our AI is trained on EU cosmetic regulations and can analyze a label image in detail. But some compliance aspects require physical product testing or access to confidential formulation data.

What our AI can determine

Read and extract label text

OCR extraction of all visible text from label images, including small print and multi-panel layouts.

Check INCI nomenclature

Validate ingredient names against the INCI dictionary, verify descending concentration order.

Verify allergen declarations

Cross-reference INCI lists against all 80+ EU fragrance allergens from Annex III.

Check Responsible Person info

Verify presence of RP name and full EU postal address on the label.

Verify PAO and expiry symbols

Detect Period After Opening symbols, best-before dates, and proper formatting.

Evaluate claims against EC 655/2013

Flag prohibited claims, absolute statements, and potentially misleading language.

Check language requirements

Verify mandatory information is provided in the official language(s) of target markets.

Validate recycling and safety symbols

Check for required symbols like Triman (France), CE marking, and hazard pictograms.

What requires human expertise

Verify formulation accuracy

We cannot confirm that the INCI list matches the actual product formulation. Only lab analysis can do this.

Test the physical product

Stability testing, microbiological testing, and physical safety assessments require a laboratory.

Confirm ingredient concentrations

Allergen thresholds (10 ppm / 100 ppm) cannot be verified from a label alone — this requires formulation data.

Review the Product Information File

The PIF, safety assessment, and CPNP notification are off-label compliance requirements we cannot inspect.

Perform toxicological assessments

Safety assessments under Annex I of EC 1223/2009 require a qualified safety assessor, not AI.

Guarantee regulatory outcome

Market surveillance decisions are made by human authorities. Our report is decision support, not a legal guarantee.

Usage Guidance

How to use your report

A LabelCheck report is designed to accelerate your compliance workflow — catching issues early so you can fix them before they become costly.

1

Screen before submission

Run your label through LabelCheck before sending it to your Responsible Person or regulatory consultant. Catch obvious issues (missing RP address, wrong INCI order, undeclared allergens) before they slow down the review process.

2

Prioritize by severity

Each issue is rated CRITICAL, MAJOR, or MINOR. Focus on critical issues first — these can block market access entirely. Major issues risk fines and recalls. Minor issues are best-practice improvements.

3

Share with your team

Forward the report to your packaging designer, RP, and quality team. Each issue includes the specific regulation reference and a recommended fix, so everyone knows exactly what needs to change.

Important Disclaimer

LabelCheck reports are decision-support tools and do not constitute legal or regulatory advice. Our AI analysis identifies potential compliance issues based on visible label content, but it cannot replace the judgment of a qualified Responsible Person or regulatory affairs professional. Always consult with a qualified expert for final compliance decisions before placing products on the market.

Regulatory Update

Why the expanded allergen rules matter

EU Regulation 2023/1545 is one of the most significant changes to cosmetic labelling in the past decade. Here is what you need to know.

26Before 2023

The original Annex III listed 26 fragrance allergens requiring mandatory declaration on cosmetic labels.

80+After Regulation 2023/1545

The updated list now includes 80+ fragrance allergens, with new declaration thresholds of 0.001% (10 ppm) for leave-on and 0.01% (100 ppm) for rinse-off products.

!Compliance Deadlines

July 31, 2026: All new products must comply.
July 31, 2028: All existing stock must comply.

Why this makes AI-powered checking essential

Manually cross-referencing 80+ allergens against an INCI list is tedious and error-prone

New allergens include substances like Methyl salicylate and Atranol that many brands haven't tracked before

Fragrance compositions often contain undisclosed sub-ingredients that may trigger declaration requirements

The cost of non-compliance (recalls, RAPEX alerts, retailer delistings) far exceeds the cost of checking

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LabelCheck reports are decision-support tools and do not constitute legal or regulatory advice. Always consult with a qualified Responsible Person or regulatory affairs professional for final compliance decisions.

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