Missing or incorrect Responsible Person details

Every cosmetic product placed on the EU market must identify a Responsible Person (RP) established within the EU. The label must state the RP’s name and address — not just a brand name or website. A company registered in the UK post-Brexit can no longer act as RP for EU distribution. This is the single most frequent non-compliance issue for products entering via e-commerce.

Incorrect or missing country of origin for imported products

Regulation (EC) No 1223/2009 requires that the country of origin be clearly stated on the labelling of cosmetic products imported into the EU. Vague or overly broad geographical references do not satisfy this requirement and may result in market surveillance actions, including product withdrawal.

Incorrect minimum durability or PAO indication

Products with a shelf life under 30 months must display a “best before” date using the hourglass symbol followed by date. Products lasting longer must show a Period After Opening (PAO) symbol — the open-jar icon — with the number of months (e.g. “12M”).

A frequent error is using PAO for products with a shelf life under 30 months, or omitting PAO entirely for long-life products. Both are non-compliant.

Ingredient list not in INCI nomenclature

The ingredient list must use International Nomenclature of Cosmetic Ingredients (INCI) names — not common names, trade names, or marketing language. Ingredients must be listed in descending order of weight at the time of incorporation. Perfume and aromatic compositions may be listed simply as “Parfum” or “Aroma,” but allergens above threshold concentrations must be declared individually, even within fragrance mixes.

Insufficient font size or illegible text

All mandatory label information must be indelible, easily legible, and clearly visible. While the regulation does not specify an exact minimum point size, national guidance and industry practice treat 0.9mm lower-case letter height as the practical threshold. Information on very small containers that cannot fit all mandatory data on the physical label may use a leaflet or card, but must still include certain elements on the pack itself.

Claims not substantiated or prohibited claims used

Cosmetic products may not claim medicinal properties, suggest they cure or treat conditions, or use comparative claims without substantiation. The EU’s Common Criteria Regulation sets six principles all cosmetic claims must satisfy: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making.

Phrases like “clinically proven,” “dermatologist tested,” or “eliminates bacteria” routinely fail substantiation requirements or imply medical efficacy.

Language requirements not met

Labels must be in the official language(s) of the member state(s) where the product is sold. Warnings, precautions, and directions of use must be translated. Ingredient lists may use INCI names which are internationally standardised, but all other mandatory particulars require a local-language version.

Selling a product intended for the Greek or French market with English-only warnings is a clear violation.

Missing or incorrect precautionary statements for specific ingredients

A number of cosmetic ingredients are permitted only with specific labelling conditions. Hydrogen peroxide in hair products, retinol, and certain other ingredients all carry mandatory on-label warnings set out in the annexes to the Regulation.

Failure to include them — even if the product is otherwise compliant — constitutes a direct breach of the conditions of use.

Batch number absent or non-traceable

A batch number or other reference to identify the manufacturing batch must appear on the label. This is a core traceability requirement enabling market recall actions. The batch code must exist on both the primary and secondary packaging, and the manufacturer must be able to decode it to identify production date, site, and raw material lot.

Generic codes repeated across unrelated product runs do not satisfy this requirement.

Nano-ingredient declarations missing

Ingredients in nanomaterial form must be clearly indicated in the ingredient list. The word “nano” must follow the INCI name in brackets — for example, “Titanium Dioxide (nano).” This requirement is frequently overlooked because the nano status of an ingredient may not be apparent from supplier documentation. Brands must actively verify particle size characterisation in safety data.

CPNP notification errors or omissions

Before a cosmetic product is placed on the EU market, the Responsible Person must submit a notification through the Cosmetic Products Notification Portal (CPNP). Errors here are more common than many brands expect: notifying with an incomplete or outdated formula, failing to update the notification after a reformulation, submitting under the wrong product category, or — critically — placing the product on the market before the notification is accepted. For products containing nanomaterials, a separate 6-month prior notification is required under Article 16, and this step is frequently missed entirely.

A product on-shelf with an absent or incorrect CPNP notification is non-compliant regardless of how accurate the physical label is.

Labelling compliance is not a one-time project. The annexes to Regulation 1223/2009 are amended regularly through Commission regulations, and ingredients that were permitted without restriction can suddenly require specific warnings or be subject to concentration limits. Any label must be reviewed against the current version of the annexes at the point of placing on the market — not at the point of initial development.

For multi-market products, it is strongly recommended to develop a master label specification that identifies every mandatory and optional element, maps it to the relevant article, records the evidence supporting any claim, and assigns a language version for each target member state. A rolling review schedule should be tied to product reformulation, ingredient supplier changes, and regulatory updates.

The same discipline applies to CPNP notifications. Brands should maintain an internal register of all notified products, recording the notification date, product category, formula version, and any subsequent updates. When a formula changes — even marginally — the notification must be reviewed and amended accordingly.

ELINEK can review your cosmetic products for full EU compliance

Our team of cosmetic regulatory specialists offers label assessment, INCI verification, claims substantiation review, CPNP notification support, and safety evaluation for the Greek and EU markets.

Whether you are bringing a new product to market or auditing an existing range, we are here to help.