Understanding Labelling Legislation

Some of our most frequently asked questions are regarding labelling, it seems to confuse the best of us, how to list ingredients and what information needs to be included especially, so here’s a quick guide to simplify things.

 

All cosmetic products in the UK are covered by the REGULATION (EC) No 1223/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (you can read it here)

The above regulations make reference to the “responsible person”, this is generally the manufacturer or person who has such a product designed or manufactured, and markets that cosmetic product under their name or trademark;

As the responsible person you must comply with the regulations associated with manufacturing and/or selling of cosmetic products.

So let’s take a look at the regulations; Article 19 – Labelling

Mind boggling right?

So let’s break it down;

  1. The following information must be on the container and packaging in clear, indelible print. If you need a magnifying glass to read it’s no good.
    • a)  The name and address of the “responsible person” this is the person named on the CPSR (Cosmetic product safety report), the CPNP (Cosmetic product notification portal) and where your PIF (product information folder) is held.
    • b)  The weight / volume of the product must be clearly displayed on the product and packaging.
    • c)  A best before date.

So a bit more on how you work out a best before date, our friends at Cosmetic Safety Consultants Ltd. have this info in their helpful labelling guide;

Product Shelf Lives and Labelling

In general, anhydrous product (without water) can be described as nominally stable for 30 months, which means that a Best Before End (BBE) date is not required. This assumes that the product is kept in a sealed container, in a cool place, away from direct sunshine. In this case the PAO symbol can be used on your labelling. In practice, for small scale producers, we would advise the following general shelf lives (taking into account the production of small batches, and having products on display at markets etc.)

 

Lip Balms – BBE 24 months after manufacture, Use within 6 months of opening

Body Butters – BBE 24 months after manufacture, Use within 6 months of opening

Oils – BBE 24 months after manufacture, Use within 6 months of opening

Bath Bombs – BBE 12 months after manufacture, Use within 6 months of opening

Bath Salts – BBE 24 months after manufacture, Use within 6 months of opening

M&P soaps – PAO symbol – 6 months – No BBE required

CP/HP soaps – PAO symbol – 6 months – No BBE required

Emulsions (creams and lotions) – see assessment document for details

BBE – the Minimum Durability symbol can be used instead of “Best Before” if preferred, with accompanying date

 

These are the symbols mentioned in  point 3 of Annex VII 

  1. Period-after-opening (POA)

 

 

 

 

  1. Date of minimum durability

 

 

 

 

 

d) Any precautions must be listed on the label, these may be relevant to the use of product or because of ingredients. Annexes II to VI are huge, (1000’s of substances listed) so you’ll need find a comfy chair and grab a large cup of tea if you want to read the regulations yourself and make sure you are adhering to the rules.

The main ones to be aware of are;

  • ‘Rinse-off product’ means a cosmetic product which is intended to be removed after application on the skin, the hair or the mucous membranes;
  • ‘Leave-on product’ means a cosmetic product which is intended to stay in prolonged contact with the skin, the hair or the mucous membranes;
  • ‘Hair product’ means a cosmetic product which is intended to be applied on the hair of head or face, except eye lashes;
  • ‘Skin product’ means a cosmetic product which is intended to be applied on the skin;
  • ‘Lip product’ means a cosmetic product which is intended to be applied on the lips;
  • ‘Face product’ means a cosmetic product which is intended to be applied on the skin of the face;
  • ‘Nail product’ means a cosmetic product which is intended to be applied on nails;
  • ‘Oral product’ means a cosmetic product which is intended to be applied on teeth or the mucous membranes of the oral cavity;
  • ‘Product applied on mucous membranes’ means a cosmetic product which is intended to be applied on the mucous membranes

– of the oral cavity,
– on the rim of the eyes,
– or of the external genital organs;

(e) the batch number. This is the number or reference you assign to your product when you are making it, on each separate occasion (batch). If your product is too small to display the batch number, you can put it on the packaging only;

(f) the function of the cosmetic product, unless it is clear from its presentation;

(g) a list of ingredients. This information may be indicated on the packaging alone. The list shall be preceded by the term ‘ingredients’.

There are further rules when it comes to ingredients;

  • Ingredients need to be listed in descending order of concentration.
  • Ingredients in concentrations of less than 1 % may be listed in any order after those in concentrations of more than 1 %.
  • Ingredients must be listed using the INCI name – International Nomenclature of Cosmetic Ingredients.
  • There is nothing to stop you using the common name in brackets alongside, so that your customers know exactly what you are using. For example “Lavandula angustifolia (Lavender) flower oil” is perfectly acceptable)
  • Colourants other than colourants intended to colour the hair may be listed in any order after the other cosmetic ingredients. For decorative cosmetic products marketed in several colour shades, all colourants other than colourants intended to colour the hair used in the range may be listed, provided that the words ‘may contain’ or the symbol ‘+/-’ are added. The CI (Colour Index) nomenclature shall be used, where applicable.
  • Perfume (fragrance oils) and aromatic compositions and their raw materials shall be referred to by the terms ‘parfum’ or ‘aroma’.
  • In the case of soap, bath bombs and other small products where it is impossible for practical reasons for the information to appear on a label, tag, tape or card or in an enclosed leaflet, this information shall appear on a notice in immediate proximity to the container in which the cosmetic product is exposed for sale.
  • Any allergens present in the product.

 

Here is a great example from our friends at Cosmetic Safety Consultants Ltd

The following example is for a simple anhydrous balm with the following formulation;

35% Sweet almond oil
18% Jojoba oil
27% Mango butter
15% Jojoba wax
4% Cetyl Alcohol
1% Vitamin E
1% Lavender essential oil

Putting the ingredients into descending order and using the INCI name, the ingredient label would read;

Prunus Amygdalus Dulcis, Simmondsia Chinensis Seed Oil, Mangifera Indica Seed Butter, Simmondsia
Chinensis Seed Cera, Cetyl Alcohol, Tocopherol, Lavandula Angustifolia Oil.

 

Allergens

Because it includes an essential oil (the same applies to fragrance oils) the label also needs to include Allergens.

There are 26 allergens that occur in fragrances and essential oils that need to be included on the ingredients list if they are present at or above a certain concentration (0.01% for wash off products like soap, 0.001% for leave on products like body butters and creams).

Your supplier should provide you with an allergen declaration – this tells you if any of the 26 allergens are present, and at what concentration.

Here is an example of what an Allergen Declaration may look like 

So how does this translate to the label?

From the document above, the lavender essential oil contains the following allergens

Geraniol – 1%
Limonene – 1%
Linalool – 36.7%

Lavender is included at 1% in the formulation, so we can calculate the following –

Geraniol is present at (1% x 1%) = 0.01% in the final product
Limonene is present at (1% x 1%) = 0.01% in the final product
Linalool is present at (36.7% x 1%) = 0.367% in the final product

 

As this is a leave on product, all three allergens need to be labelled, because they are all present above 0.001%, so our final ingredients label reads:

Prunus Amygdalus Dulcis, Simmondsia Chinensis Seed Oil, Mangifera Indica Seed Butter, Simmondsia Chinensis Seed Cera, Cetyl Alcohol, Tocopherol, Lavandula angustifolia (lavender) oil, Linalool, Limonene, Geraniol.

 

So following all the legislation the finished label would look like this;

 

We offer these guidelines based upon our own experiences and understanding of the law as it currently stands in the UK.

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