Cosmetic labelling: all requirements of Regulation 1223/2009
Regulation (EC) No 1223/2009 on cosmetic products defines the labelling requirements applicable to any cosmetic product placed on the EU market. Creams, shampoos, perfumes, makeup, sunscreens: all these categories are subject to the same basic requirements, supplemented by specific mentions depending on the formula and use. Here is the complete detail of the 10 mandatory mentions.
1. Name and address of the responsible person
Every cosmetic product marketed in the EU must state the name and address of the "responsible person" — the legal or natural person established in the EU who assumes regulatory responsibility for the product. For products imported from outside the EU, the importer or distributor established in the EU becomes the responsible person by default.
2. Nominal content
The content by weight or volume must appear on the packaging, except for presentations containing less than 5 g or 5 ml, free samples and single-use doses. For multi-packs (gift sets, kits), the content of each individual product must be indicated.
3. Best before date or PAO
For products with a shelf life of less than 30 months, the BBD ("Best used before end of...") is mandatory. It is accompanied by the hourglass symbol and the date or the location of the date on the packaging.
For products with a shelf life exceeding 30 months (the majority of cosmetics), the BBD is replaced by the PAO — Period After Opening — symbolized by the "open jar" icon and expressed in months (e.g. "12 M").
4. Precautions for use and special warnings
Certain cosmetic ingredients listed in Annexes III, IV, V and VI of the regulation require mandatory warnings on the label. Examples:
- Hydrogen peroxide in hair colorants: "Contains hydrogen peroxide"
- Phenoxyethanol (if > 1%) in products for children under 3: paediatric warning
- Sunscreen products: protection factor, application advice, prolonged exposure warning
- Products containing nanomaterials: "nano" in brackets in the INCI list
- Fragrances: "contains [fragrance allergen name]" for the 26 allergens in Annex III
5. Batch number
The batch number enables product traceability and targeted recall in case of non-compliance. It must appear on the container or, failing that, on the secondary packaging.
6. Product function
The cosmetic function of the product must be indicated, unless it is clearly evident from the product presentation.
7. Ingredients list (INCI)
The ingredients list must use INCI nomenclature (International Nomenclature of Cosmetic Ingredients) and present components in descending order of their concentration.
| Situation | INCI listing rule |
|---|---|
| Concentration > 1% | Descending order mandatory |
| Concentration ≤ 1% | Free order (after > 1%) |
| Colorants | Can be listed at the end with CI code |
| Nanomaterials | "[nano]" in brackets after the INCI name |
| Composite fragrances and flavours | "Parfum" or "Aroma" (without composition detail) |
8. Language and legibility
Mandatory information must be written in the official language(s) of the Member State of marketing. For France, French is mandatory.
The minimum character height is 0.9 mm (x-height) for mandatory information.
9. Separate leaflet availability (small packaging)
When the primary packaging is too small to accommodate all mandatory mentions, certain information may be transferred to a leaflet, label, tape or card attached to the product.
Safety mentions (precautions for use, warnings) can never be moved to a separate leaflet: they must always appear on the packaging directly accessible to the consumer.
10. "Cosmetic" mention and CPNP compliance
Before marketing in the EU, each cosmetic product must be notified in the European CPNP portal (Cosmetic Products Notification Portal). Failure to notify is an offence subject to penalties.
The 83 fragrance allergens (Reg. 2023/1545)
Regulation (EU) 2023/1545 of 26 July 2023, amending Annex III to Regulation (EC) 1223/2009, extends the list of allergenic fragrance substances that must be declared on labelling. The list increases from 26 to 83 individual substances requiring mandatory declaration.
This regulation aims to strengthen protection for consumers sensitised to fragrance allergens, based on the opinions of the Scientific Committee on Consumer Safety (SCCS).
Application dates
The regulation provides for two deadlines:
- 1 August 2026 — for new products placed on the market from this date.
- 1 August 2028 — for products already on the market, at the next production cycle.
Declaration thresholds
Mandatory declaration thresholds:
- 0.001% (10 ppm) — leave-on products: creams, serums, perfumes, deodorants.
- 0.01% (100 ppm) — rinse-off products: shower gels, shampoos, soaps.
Above these thresholds, each substance must appear individually in the INCI list.
The 10 most common allergens
These ten fragrance allergens are the most frequently found in cosmetic formulations:
| Allergen (INCI) | Typical natural sources |
|---|---|
| Linalool | Lavande, bois de rose, coriandre |
| Limonene | Agrumes (citron, orange, pamplemousse) |
| Citronellol | Rose, géranium, citronnelle |
| Geraniol | Rose, palmarosa, géranium |
| Citral | Lemongrass, verveine, mélisse |
| Coumarin | Fève tonka, lavande, cannelle de Chine |
| Eugenol | Clou de girofle, cannelle, basilic |
| Benzyl Alcohol | Jasmin, ylang-ylang |
| Cinnamal | Cannelle de Ceylan, cassia |
| Farnesol | Tilleul, rose, néroli, camomille |
Among the 57 newly added substances are complex natural mixtures and numerous terpenes found in essential oils. Manufacturers using natural fragrances must obtain from their suppliers the full declaration of allergens above the thresholds.
Common cosmetic labelling errors
Automated analysis of hundreds of cosmetic labels by LabelCheck identifies recurring non-compliances. Here are the eight most frequently detected errors.
1. Incomplete or incorrectly ordered INCI list
All ingredients must be listed in descending order of concentration (Art. 19\u00a71-g). Below 1%, the order is free.
2. Missing PAO symbol
The PAO symbol is mandatory for any product with a shelf life exceeding 30 months (Art. 19\u00a71-c).
3. Fragrance allergens not declared
Allergens must be individually declared in the INCI list above the thresholds. The generic mention "Parfum" is not sufficient.
4. Responsible Person outside the EU
Article 19\u00a71-a requires the name and address of a Responsible Person established in the EU.
5. Missing nominal content
The net weight or volume must appear on the packaging (Art. 19\u00a71-e), expressed in metric units.
6. Product function not indicated
Article 19\u00a71-f requires the product function to be stated. Often confused with a marketing slogan.
7. Missing warning statements
Hair dyes, sun protection products, fluoride products: Annexes III to VI require specific warnings.
8. Missing CPNP notification
Every cosmetic product must be notified on the CPNP portal before being placed on the EU market (Art. 13).
Check your cosmetic label compliance
LabelCheck analyses your artwork or label image and verifies the INCI list, PAO, fragrance allergens, mandatory warnings and compliance with Regulation 1223/2009.
Analyse my label →Frequently asked questions
Is a "natural" or "organic" product subject to the same requirements?
Yes, without exception. "Organic" or "natural" labels are voluntary certifications that add constraints on ingredients, but do not change the regulatory labelling requirements of Regulation 1223/2009.
Are products sold in an online shop covered?
Yes. Cosmetic products sold online to EU consumers are subject to the same labelling requirements as products sold in physical stores.
How to handle multilingual packaging?
For the same product sold in several EU countries, all languages of the marketing Member States must appear on the packaging. The INCI list in international nomenclature does not need to be translated.
What are the new mandatory allergens since 2023?
Regulation (EU) 2023/1545 adds 57 new substances, bringing the total from 26 to 83 allergens. Mandatory declaration from 0.001% (leave-on) or 0.01% (rinse-off).
My product is manufactured outside the EU — what must I indicate?
You must indicate the country of origin and the name/address of a Responsible Person established in the EU (the importer). A Product Information File (PIF) must be available.
Must the INCI list be in the local language?
No. INCI nomenclature is international (Latin/English) and identical across all EU countries. However, all other mentions must be in the official language(s) of the country of sale (Art. 19\u00a75).