Compliance Audit Report
LabelCheck
Report ID: LC-2026-0319-DEMO
March 19, 2026
Generated in 47 seconds
Product
Glow Botanics Hydrating Face Serum
Net Content
30 ml / 1.0 fl oz
Brand
Glow Botanics
Target Market
EU (France, Germany)
72 / 100
This label has 4 compliance issues that must be resolved before selling in the EU. The most critical: a missing Responsible Person address, which can result in immediate product withdrawal.
INCI Declaration (as listed on label)
Aqua, Glycerin, Aloe Barbadensis Leaf Juice, Sodium Hyaluronate, Niacinamide, Squalane, Panthenol, Tocopheryl Acetate, Linalool, Citric Acid, Sodium Benzoate, Potassium Sorbate
Compliance Checks
10 checks performed against EU Regulation EC 1223/2009 and related directives
INCI Ingredient List
Correct nomenclature per IUPAC/INCI dictionary. Descending order by concentration verified.
Net Content Declaration
30 ml properly displayed with correct unit notation per EU Directive 76/211/EEC.
Batch Number / Lot Code
Lot code present on packaging. Traceable format confirmed.
Responsible Person
EU Responsible Person address is missing from the label. CRITICAL violation of EC 1223/2009 Art. 19.
PAO Symbol (Period After Opening)
12M symbol displayed correctly with standard hourglass icon.
Allergen Declaration
Linalool detected in INCI list but not separately declared as a fragrance allergen per EC 1223/2009 Annex III.
Country of Origin
"Made in France" properly declared on packaging.
Language Requirements
French language present. German translation missing — required for German market per EC 1223/2009 Art. 19(5).
Product Claims
No prohibited or misleading claims detected per EU Regulation 655/2013 (common criteria).
Recycling Symbols
Triman symbol (French recycling mark) required for French market since Jan 2022 but not present on packaging.
Issue Details & Remediation
Each issue below includes the specific regulation, the risk to your business, and the exact fix required.
Missing EU Responsible Person Address
EC 1223/2009 — Article 19(1)(a)
Every cosmetic product placed on the EU market must display the name and address of the Responsible Person. This label lists the brand name but provides no physical EU address, email, or means of contact for the designated Responsible Person.
Risk if not fixed
Products without a Responsible Person cannot legally be sold in the EU. Customs can refuse entry, retailers will reject stock, and market surveillance authorities can order immediate product withdrawal. Fines vary by member state but can reach €45,000+ in France.
Recommended fix
Add the full name and postal address of your EU Responsible Person directly on the label or packaging. If your company is based outside the EU, you must appoint an EU-based Responsible Person (a distributor, importer, or RP service provider) and display their address.
Undeclared Fragrance Allergen: Linalool
EC 1223/2009 — Annex III, Part 1 (ref. 45)
The INCI list includes Linalool, which is one of the 80+ fragrance allergens (expanded via EU Regulation 2023/1545) that must be individually declared when present above 10 ppm in leave-on products (or 100 ppm in rinse-off). It appears in the ingredient list but is not separately called out as a fragrance allergen in the mandatory labelling.
Risk if not fixed
Non-compliance with allergen declaration requirements is treated seriously by EU authorities. This can trigger product recalls, consumer safety alerts via the RAPEX system, and retailer delistings. Repeated non-compliance can result in sanctions against the Responsible Person.
Recommended fix
Linalool is already listed in the INCI declaration. However, if it is present as a fragrance component (not added as an individual ingredient), it must still be declared as part of the fragrance allergen labelling. Verify its source and concentration, then ensure proper allergen flagging per Annex III requirements. Consider also checking for other Annex III allergens that may be present in fragrance compositions.
Missing German Language Translation
EC 1223/2009 — Article 19(5)
The product targets both France and Germany, but the mandatory label information (function, precautions, ingredients context) is only provided in French. Article 19(5) requires that certain information be provided in the official language(s) of the member state where the product is made available.
Risk if not fixed
German customs and market surveillance authorities can prohibit the sale of products without German-language labelling. Retailers in Germany (especially chains like dm, Rossmann, Douglas) will reject products that don't comply. This blocks market access entirely.
Recommended fix
Add German translations for all mandatory label elements: product function, usage instructions, warnings/precautions, and any claims. The INCI list itself remains in standardized INCI nomenclature (Latin/English) and does not need translation. Consider using a multi-panel label or booklet label if space is limited.
Missing Triman Recycling Symbol
French Environmental Code — Article R541-12-17 (AGEC Law)
Since January 1, 2022, all products sold in France (including cosmetics) must display the Triman logo along with sorting instructions (Info-tri) to guide consumers on proper waste disposal. This label does not include the Triman symbol or sorting guidance.
Risk if not fixed
Non-compliance with the Triman requirement can result in fines up to €15,000 per product reference for companies. French retailers increasingly require this symbol as a condition of listing. While enforcement has been gradual, it is tightening in 2026.
Recommended fix
Add the Triman symbol (a figure with a circular arrow) and the associated Info-tri sorting instructions to your packaging. You can obtain the correct Info-tri pictograms from CITEO (the French EPR scheme). Ensure the symbol is at least 6mm in height and clearly visible.
Audit Summary
| Category | Status | Regulation |
|---|---|---|
| INCI Nomenclature | PASS | EC 1223/2009 Art. 19(1)(g) |
| Net Content | PASS | EU Dir. 76/211/EEC |
| Batch / Lot Code | PASS | EC 1223/2009 Art. 19(1)(c) |
| Responsible Person | FAIL | EC 1223/2009 Art. 19(1)(a) |
| PAO Symbol | PASS | EC 1223/2009 Art. 19(1)(d) |
| Allergen Declaration | FAIL | EC 1223/2009 Annex III |
| Country of Origin | PASS | EC 1223/2009 Art. 19(1)(a) |
| Language Requirements | WARN | EC 1223/2009 Art. 19(5) |
| Claims Compliance | PASS | EU Reg. 655/2013 |
| Recycling Symbols | FAIL | FR AGEC Law Art. R541-12-17 |
More sample audits
Every product type gets the same thorough analysis. Here are two more examples.
Sample Report #2
SolShield SPF 50 Face Sunscreen
50 ml · Target: EU (Spain, Italy) · Score: 58/100
SPF claim without required UV-protection warnings
EC 1223/2009 — Art. 19; Commission Recommendation 2006/647/EC
Label claims SPF 50 but lacks mandatory usage instructions for sun protection products including "does not provide 100% protection" and reapplication guidance.
Missing Spanish and Italian language translations
EC 1223/2009 — Art. 19(5)
Product targets Spain and Italy but mandatory label information is only in English. Both countries require labelling in their official language.
Potentially misleading "waterproof" claim
EU Claims Regulation 655/2013 — Common Criteria
"Waterproof" is generally considered misleading for sunscreens under EU guidelines. Consider "water-resistant" with supporting test data.
Sample Report #3
PureRoot Strengthening Shampoo
250 ml · Target: EU (Germany, Austria) · Score: 91/100
"Clinically tested" claim without visible substantiation reference
EU Claims Regulation 655/2013 — Truthfulness (Art. 3)
The claim "clinically tested" appears on the label. While not prohibited, best practice under 655/2013 is to reference the test or make supporting data available. Low risk but recommended improvement.
9 of 10 checks passed
This label is nearly market-ready. One minor improvement recommended.
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This sample report is for demonstration purposes only and was generated for a fictional product. LabelCheck reports are intended as guidance and do not constitute legal advice. Always consult with a qualified regulatory professional for final compliance decisions.
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