Cosmetic labelling 2025: 7 rules you need to know to avoid fines

Cosmetic labelling will be the subject of growing controls by competent authorities. The growing attention of the European Union toward transparency, consumers’ safety and sustainability requires a continuous and dedicated adjustment by the companies of the sector.

We will examine here the 7 fundamental rules for cosmetic labelling, providing practical advice to comply with the EU cosmetic Regulation and avoid sanctions.

1. Mandatory indications: what they should always be reported in the label

Article 19 of Regulation (EC) 1223/2009, currently in force, establishes the obligations for cosmetic labels. The following information must never be missing:

name or registered name and the address of the responsible person
country of origin (for extra-EU products)
nominal weight/volume
date of minimum durability or PAO (Period After Opening)
precautions for use
batch number of manufacture or reference
function of the cosmetic product (if unclear)
list of ingredients (INCI)

2. Pay attention to the characters: readability above all

Controls on label readability are becoming stricter. Authorities will request:

Permanent, readable and visible characters
Mandatory translation into the language of the country of marketing

The label must be clear and easily understandable by the average consumer.

3. How to label a cosmetic product containing allergens and nanomaterials

In 2025 it will become mandatory to state some new allergens in the label, following the updating of the SCCS (Scientific Committee on Consumer Safety) opinions.

Moreover, nanomaterials shall be clearly indicated with the wording “[nano]” next to the INCI name.

4. Acceptable cosmetic claims: what can (and cannot) be said

Cosmetic claims should be:

true
not misleading
supported by adequate evidence
consistent with the functions of a cosmetic product (not ascribable to medicinal products or medical devices)

Examples of some issues: “it cures acne”, “medical effect”, “with no chemicals” (the latter is strongly criticised by several Member States). Green communication is under scrutiny: the use of environmental claims with no foundation may involve sanctions for misleading advertising.

5. Symbols and icons: only if appropriate and acknowledged

It is possible (and often useful) to include symbols such as:

PAO (open container)
Symbols regarding environmental labelling
Hourglass for the expiry date

According to the regulations, the cruelty-free leaping bunny is forbidden by the European Regulation 655/2023, as well as the wording “Not tested on animals” because it is misleading. In fact, according to the European regulation, it is forbidden to import or manufacture cosmetic products tested on animals.

Beware: improper use of these symbols can be considered as an unfair marketing practice.

6. Packaging and sustainability: toward the PPWR regulation

In the context of environmental transition, environmental labelling is becoming more and more relevant.

In 2025, the provisions of the new EU regulation on packaging (PPWR) will become effective. Manufacturers shall ensure:

clear information on disposal
use of recyclable materials
reduction of unnecessary packaging

7. Continuous update of labels and documentation

Companies should ensure that labels are consistent with the PIF (Product Information File) and with the notifications in the European cosmetic portal CPNP.

Every regulating change (e.g. restrictions on ingredients, changes to claims) involves a verification and update of the label and its notification in the CPNP, possibly supported by a regulatory consultancy.

Why it is important to follow these rules

Compliance with the obligations for the labels of cosmetic products is not only a regulatory duty, but also a guarantee of professionalism and transparency to consumers.

Labelling is often the first element that is verified during the controls of health authorities and customs: erroneous claims may lead to fines, while the presence of hazardous ingredients, or the reporting of serious adverse reactions may lead to market withdrawal, along with sanctions and reputation damage.

How can we help?

We offer customised services:

assessment of conformity of the composition according to the EU Cosmetic Regulation
review of labels according to the regulations in force
control of claims and supporting documentation
assistance in drafting the PIF (Product Information File)
assistance for the registration of the company and notification of cosmetic products in the CPNP portal
monitoring of regulation updates