Regulatory compliance for cosmetic products depends heavily on accurate and standardized ingredient labelling. The cosmetic label is the main point of communication between the manufacturer and the consumer. It provides essential information related to product safety, proper use, and informed purchasing decisions. In the European Union, compliance with Regulation (EC) No 1223/2009 is mandatory for all cosmetic products placed on the market.
The INCI Standard and Ingredient Uniformity
The foundation of cosmetic ingredient labelling is the mandatory use of INCI (International Nomenclature of Cosmetic Ingredients) names. INCI provides a globally harmonized naming system that ensures consistency across all markets, regardless of local language requirements. For example, water is always declared as “Aqua,” and preservatives or functional ingredients must be listed by their standardized INCI names rather than trade or brand names.
Ingredients must be listed in descending order of weight at the time the formulation is prepared. The ingredient used in the highest concentration appears first on the list, while the ingredient used in the lowest concentration appears last.
Rules for Low-Concentration Ingredients and Colorants
EU cosmetic legislation allows specific exceptions to the standard descending order rule to reflect formulation realities.
Ingredients present at concentrations below 1% may be listed in any order after all ingredients used at 1% or higher. This flexibility avoids frequent label changes caused by minor formulation adjustments at very low levels.
Colorants follow separate rules. They are always listed at the end of the ingredient list and must be identified by their Colour Index (CI) numbers, such as CI 77891 for titanium dioxide. For decorative cosmetics sold in multiple shades, manufacturers may list all colorants used across the range. In such cases, the list is preceded by the phrase “May contain” or the ± symbol.
Fragrance and Aroma Declarations
Fragrance and aroma ingredients are generally declared using the terms “Parfum” or “Aroma.” However, this rule has important limitations. If a fragrance mixture contains any allergenic substances listed in Annex III of Regulation (EC) No 1223/2009, those substances must be declared individually. This applies when their concentration exceeds defined threshold levels, even if they are only present as part of the fragrance composition.
Placement and Legibility Requirements
The ingredient list must be clearly visible, easy to read, and indelible on the cosmetic packaging. When the primary packaging is too small to display the full ingredient list, the information must be provided on an attached leaflet, label, or tag. In such cases, the packaging must display the “Refer to Enclosed Information” symbol to guide consumers.
Ensuring Ongoing Compliance
Ingredient labelling compliance requires careful attention to INCI nomenclature, correct sequencing, allergen disclosure, and proper label placement. Accurate and transparent ingredient lists help protect consumer safety, support regulatory inspections, and ensure uninterrupted access to the EU cosmetics market.
From INCI nomenclature to allergen thresholds, we support your cosmetic labelling compliance in the EU. Get in touch today.
