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Cosmetic Labelling: The 10 Most Common Mistakes, Explained Simply
Are you preparing your first cosmetic range, or reworking the label of a product that already exists? What you print on a bottle is not just design. It is a text governed, item by item, by a European law: Regulation (EC) No 1223/2009. If a piece of information is missing or wrongly worded, the product can be held at customs, pulled from sale or rejected by a retailer even when the formula is faultless.
The good news: the mistakes are almost always the same ones. Here are the ten most frequent, explained simply, with what to check each time. No prior knowledge required we define the vocabulary as we go.
The vocabulary you need before you start
Responsible Person (RP) : the company that answers for the product before the authorities. Every cosmetic placed on the market of the European Union (and the EEA) must have one, established in that territory. This status comes from the Regulation manufacturer, importer, or a company appointed by written mandate and not from what is printed on the label.
Contract manufacturer : the factory that makes the product on behalf of the brand. It is not necessarily the Responsible Person.
PIF (Product Information File) : the file holding the product description, the safety report, the manufacturing method and GMP compliance, the evidence for claimed effects where the nature of the product justifies it, and animal-testing data. It must remain accessible to the authorities for ten years after the last batch is placed on the market.
Artwork proof : the final packaging layout, the one signed off just before printing. After that, every change is expensive.
INCI : the international nomenclature of cosmetic ingredients. In the EU, the binding reference is the glossary of common ingredient names published by the Commission, based on INCI: water is written « Aqua », shea butter « Butyrospermum Parkii Butter ». Careful, it does not transfer as it stands outside Europe: the FDA requires « Water » and « Fragrance » where the EU writes « Aqua » and « Parfum ».
Placing on the market : the first supply of a unit on the EU market in the course of a commercial activity. It is neither the manufacturing date nor the launch date of the range. Not to be confused with making available, which covers every later supply, including the sale to the consumer. The distinction is decisive whenever a text sets different deadlines for the two.
DGCCRF : the French authority that inspects products on the shelf and sanctions non-compliance. Every member state has its equivalent.
Worth remembering before you read on: a compliant label does not only protect the consumer, it protects the company. When something goes wrong, it is the first document you will be asked for — before the formula itself.
« The nine items every cosmetic label must carry in the European Union »
1. It is unclear who actually answers for the product
In short: one company must be clearly identifiable as answering for the product, and its address must be legible on the packaging.
The name and address of the Responsible Person must appear on the container (the bottle, the tube) and on the outer packaging (the carton). The address may be abbreviated, provided it still identifies the company and allows post to reach it: a well-known town can be enough if ordinary mail gets there, but a website address, which is not a postal address, does not meet the requirement. Where several addresses appear factory, distributor, brand the Regulation requires the one where the Product Information File is kept available to the authorities to be highlighted. It prescribes no method: industry guidelines use underlining, and bold or an identifying wording work just as well.
The classic mistake: the brand lets only the contract manufacturer's address be printed and its own name disappears. An important point: it does not stop being the Responsible Person that status comes from the Regulation and the written mandate, not from the label. But the labelling becomes non-compliant, and an inspection will turn first to the company identified on the pack.
2. The country of manufacture is missing
In short: if the product is imported that is, manufactured outside the European Union the country of origin must be stated.
The test is not geographical in the everyday sense: a product made in the United Kingdom or in Switzerland is made in Europe, yet remains an imported product for which the statement is mandatory. The Regulation imposes no set wording; in practice you write « Made in China », and for the French market the French wording is the safer option under the law on the use of the French language. The statement is often forgotten on white-label products bought ready-made from a foreign supplier, although it is one of the first points checked on entry.
The reverse mistake: writing « Made in France » when only the filling takes place there. To claim an origin, the product must have undergone substantial transformation there, not merely packaging. Otherwise the statement becomes misleading and exposes you under unfair commercial practices rules.
3. Confusing the durability date with the period after opening
In short: there are two ways of saying how long the product stays safe, and the stability duration demonstrated by testing decides which one applies.
It all starts with stability testing: laboratory work measuring how long the product remains stable. If the minimum durability is 30 months or less, you display a date of minimum durability: the wording « Best used before end of » followed by the date, or the hourglass symbol. The date is made up, in this order, of the month and the year, or the day, the month and the year. If durability exceeds 30 months, that date is no longer required: instead you show a period after opening (PAO), the open-jar symbol followed by a duration expressed in months and/or years 6M, 12M, 24M. That is how long the product remains safe after opening and can be used without harm to the consumer.
The most common mistakes:
Putting a PAO on a product that is only opened once single dose, sample, sealed aerosol: the concept is not relevant, so no open-jar symbol. Careful, this exemption covers the PAO only: if the product's durability is 30 months or less, the durability date remains mandatory.
Showing 24M when the laboratory only tested stability over 12 months. The stated duration must always be backed by real testing.
Writing an ambiguous date. The month/year format is allowed, but « 03/26 » reads equally as March 2026 or the year 2003: a four-digit year, « 03/2026 », removes the doubt.
Showing both at once. The Regulation does not expressly forbid it, but industry guidelines call for one or the other: durability date alone below 30 months, PAO alone above. Showing both blurs the message and attracts scrutiny.
« Durability date or PAO: how to choose in a single question »
4. The ingredient list is written incorrectly
In short: the ingredient list follows precise rules of wording and order. It is not a copy-paste of the supplier's sheet.
The list must be preceded by the word « Ingredients ». One point for the French market: the French version of the Regulation uses the accented form « Ingrédients », as does the DGCCRF guidance. But this item is not among those whose language the Regulation leaves to national law, which is why industry guidelines take the view that the term does not have to be translated. Both spellings are widely used in France pick one and keep it across the range.
Then comes the list itself, in INCI, in descending order of weight at the time the ingredients are added to the formula not according to their content in the finished product. Below 1%, the order is free, but every ingredient above 1% must come first. Colorants other than those intended to colour hair or facial hair may be grouped at the end of the list, outside the weight order, under their CI number where one exists; for a make-up product sold in several shades they may be grouped behind « may contain » or « +/- ». Finally, an ingredient present as a nanomaterial within the meaning of the Regulation insoluble or bio-persistent, intentionally manufactured, between 1 and 100 nanometres carries « [nano] » straight after its name.
The classic mistake: taking the supplier's list as it stands. It is often written in trade names « organic sweet almond oil » rather than INCI « Prunus Amygdalus Dulcis Oil ». It is the single most common source of non-compliance we come across.
5. Fragrance allergens are not declared
In short: some fragrance molecules cause allergies. Above a very small amount, they must be named in the ingredient list so that the people concerned can spot them.
The thresholds are very low: 0.001% for a leave-on product (a cream, a serum) and 0.01% for a rinse-off product (a shower gel, a shampoo). Below that, the molecule stays covered by the word « Parfum ». Above it, it must appear under its own name.
What changed recently: Regulation (EU) 2023/1545 added 56 substances to be named, taking the list from 26 to 82. Since 1 August 2026, a non-compliant product can no longer be placed on the EU market. Units already placed on the market before that date that is, already supplied by the Responsible Person, whether on the shelf or still in a warehouse may be sold through until 31 July 2028. In practice, bringing a range into compliance takes four steps: ask your fragrance house again for the list of allergens present, recalculate the percentages formula by formula, update the Product Information File, then reprint the packaging.
« Declaration thresholds and the two dates to remember »
6. The quantity is stated incorrectly
In short: the weight or volume shown is the one at the moment the product goes into its container, in grams or millilitres.
Some cases are exempt: containers under 5 g or 5 ml, free samples and single-dose units. For a gift set whose overall weight or volume is not meaningful, the quantity may be replaced by the number of items and even omitted if that number is visible from the outside or if the product is normally sold singly.
The classic mistake: adding the small « e » seen next to quantities on many packs, because « it looks professional ». The mark is optional, but by using it the packer or importer makes a commitment: the average quantity of the batch is correct, negative errors stay within tolerance, and self-checks are recorded and available to the authorities. Printing it without meeting those conditions is a non-compliance in itself — under metrology rules, not the Cosmetics Regulation. It also cannot appear on a container under 5 g or 5 ml.
7. Warnings are shortened or left untranslated
In short: each country sets the language of four statements, and certain warnings must be copied word for word.
The Regulation leaves each member state to decide the language of four statements the quantity, the durability date, the precautions for use and the function of the product as well as of any information moved onto an enclosed leaflet. In France, those four must be in French. The ingredient list is not concerned: it stays in INCI, an international nomenclature rather than an English version.
Separately, the Regulation imposes ready-made warning sentences for certain ingredients: UV filters, preservatives, hair colorants. These are copied verbatim. Rewording them « to save space » is a standard source of non-compliance. If space really is short, the hand-on-open-book symbol allows the precautions for use and the ingredient list and only those two to be moved onto a leaflet, label, tape or card enclosed with or attached to the product. That carrier must genuinely accompany the product.
8. The batch number is missing or unreadable
In short: the batch number identifies the production run. If something goes wrong, it is what allows you to find exactly which products are affected.
It must appear on both the container and the packaging. The only exception: where the small size of the product makes that physically impossible, the number may appear on the packaging alone. Two traps recur: the number printed only on the shipping carton, which the consumer never sees; and the number embossed on the bottom of a tube, which wears off in use.
Why it matters: if a batch causes a problem and cannot be identified, you cannot withdraw only the affected products. You have to withdraw the whole reference.
9. Marketing promises cannot be substantiated
In short: any statement that attributes an effect or a characteristic to the product what is called a claim — must be provable, and the evidence filed in the Product Information File.
A European text sets six common criteria: compliance with legislation, truthfulness, evidential support, honesty, fairness, and informed decision-making.
In practice:
« Paraben-free », « sulphate-free » : not allowed where it amounts to denigrating a legally authorised ingredient. Saying what the product does not contain in order to imply that others are dangerous is not permitted.
« Hypoallergenic » : requires a real evidence file. Simply removing a few known allergens is not enough.
« Dermatologically tested » : assumes a test actually took place, with a dated and archived report.
« Organic » : the ingredients must be certified under the European organic farming rules; the finished product in practice falls under a private standard such as COSMOS.
« Natural » : no text defines the term or requires certification. The claim must still be substantiated, for example against ISO 16128, and the evidence filed.
At an inspection, you will not be asked what you meant, but what you can prove.
10. Forgetting the statements that come from other regulations
In short: the Cosmetics Regulation is not the only text imposing information on your packaging.
Waste sorting : in France, the Triman logo and the sorting instruction are mandatory on household packaging. Allowances exist for the small formats that are common in cosmetics: between 10 and 20 cm², only the Triman must appear on the pack, the instruction may be moved online; below 10 cm², both may be. These thresholds double for cylindrical or spherical packaging.
Aerosols : they fall under the European aerosol dispensers directive, which imposes its own flammability wording and pictograms. Beware a frequent confusion: finished cosmetics intended for the consumer are excluded from the scope of the CLP Regulation on chemicals. For an alcohol-based fragrance that is not an aerosol, there is no flammability labelling obligation at the point of sale to the consumer — transport rules do apply upstream.
Exporting to the United States : other rules apply: the quantity shown in both US and metric units, and since December 2024 a domestic contact (a US address, telephone number or electronic contact details) for receiving adverse event reports — without any need to set up a US entity. Fragrance allergen declaration is provided for by MoCRA but is not yet applicable: the FDA has published neither the rule nor the list of substances. Anticipate it, do not apply it.
Why these get missed: they do not sit with the same people inside the company. Packaging, supply chain and quality each work on their own side, and nobody feels responsible for the whole.
Three simple habits that prevent most of these mistakes
Write the mandatory statements before the artwork is designed. Give the designer the full list from the outset. Correcting a finished creative always costs more than briefing it properly.
Have the artwork checked by the Responsible Person, not by the agency. The design studio is neither Responsible Person nor distributor under the Regulation: it does not answer for compliance before the authorities. That does not release it from its contractual liability towards you, but you are the one who will have to justify the label at an inspection.
File every approved version in the Product Information File. With the date and the name of whoever approved it. That is what will let you tell, two years later, which label belongs to which batch.
Frequently asked questions
I'm starting out: what comes before I even think about the label?
Three things: knowing who the Responsible Person will be, having the product's safety assessed by a qualified assessor pharmacist, toxicologist, physician or an equivalent discipline and building the Product Information File. The label follows from that work: it is its public summary. Writing it first means risking a full reprint.
Should the list be headed « Ingredients » or « Ingrédients »?
For a product sold in France, both spellings are used. The French version of the Regulation and the DGCCRF guidance use the accented form; industry guidelines take the view that the term does not have to be translated, since it is not among the statements whose language is left to national law. Whichever you choose, stay consistent across your whole range.
Can I show both a durability date and a period after opening?
In principle no. The Regulation does not formally prohibit it, but the two answer different situations: durability date if durability is 30 months or less, PAO above that. Industry guidelines call for one or the other. Showing both is redundant and confusing for the consumer.
Can the label be in English only?
Not for a product sold in France. Four statements must be in French the quantity, the durability date, the precautions for use and the function of the product — along with any information moved onto a leaflet. The ingredient list is not subject to that language requirement: it is written in INCI, an international nomenclature. Other member states set their own language rules, so check them market by market.
Is my current packaging still sellable despite the new allergens?
Yes, subject to one condition. Units already placed on the market before 31 July 2026 that is, supplied for the first time by the Responsible Person may be sold through until 31 July 2028: a distributor can therefore keep selling that stock. However, any unit you place on the market from 1 August 2026 must carry the new labelling. What counts is the date of first supply, not the manufacturing date nor the date of sale in store.
Who is liable if there is a mistake: the brand or the factory?
The Responsible Person: it guarantees compliance and answers for it before the authorities, whatever has been agreed with the contract manufacturer or the design agency those agreements settle who pays for the reprint, not who is liable in law. The distributor nevertheless keeps its own obligations: before putting a product on the shelf, it must check that the essential statements are present, that the language requirements are met and that the durability date has not passed.
Launching a product and not sure where to start?
REGULOO supports brands across the whole regulatory chain: labelling specifications tailored to each market, line-by-line artwork review, Product Information File, safety report, and a Responsible Person mandate if you don't have one.
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