What do all these statements on a cosmetic product label actually mean?

Cosmetic manufacturers are subject to strict regulatory requirements regarding labeling. Far from being a purely administrative constraint, these statements embody transparency, trust, and a brand’s credibility with its consumers. In Europe, they are governed by Regulation (EC) No. 1223/2009, whose objective is to harmonize practices among Member States to ensure consumer safety and fair competition.

This regulation defines a list of eight mandatory statements that must appear on the packaging of any cosmetic product placed on the European market. Failure to comply with the regulations on cosmetic product labeling renders a skincare product non-compliant, which can lead to various risks for companies, such as financial penalties, damage to their reputation, and legal action.

European regulations prohibit the use of claims (text, images, or other figurative signs) that attribute to cosmetic products characteristics or functions they do not possess, both on labeling and in advertising.

Beyond the content, the regulation also imposes requirements on the format of labeling. Above all, good labeling is labeling that is legible and accessible. This implies:

• A clearly visible placement of essential information - this information must not be buried in a complex design or relegated among secondary elements.

• Optimal legibility - adequate contrast, appropriate font size, indelible characters... the information must be written in a typeface adapted to the size of the container.

• Respect for local languages - mandatory information must be written in the official language(s) of the country or countries where the product is marketed, in particular the product’s function and its precautions for use.

Well-designed labeling goes beyond mere regulatory compliance. It demonstrates transparency and professionalism, and can play a decisive role in the consumer’s purchasing decision.

When the space available on the packaging is insufficient to display all the required information, the precautions for use and the list of ingredients may appear on a separate medium (leaflet, folded label, attached card, etc.).

For brands, ensuring labeling compliance does not end with the initial drafting. Every graphic change or reformulation must undergo an updated regulatory review. The marketing and design teams involved in packaging creation must be trained in the applicable requirements (correct use of symbols, information hierarchy, mandatory warnings depending on product categories, etc.). Although Regulation (EC) No 1223/2009 does not set a minimum font size, a height of at least 1.2 mm is generally considered acceptable to ensure legibility.

Every product placed on the market, including samples, must comply with the Product Information File (PIF) and be documented in it, in accordance with the requirements of the regulation.

Beyond the mandatory legal information, cosmetic packaging is often enriched withvoluntary claims added by brands to highlight specific characteristics of their products. These statements are regulated by Regulation (EU) No 655/2013, which establishes six common criteria that every cosmetic claim must meet: compliance with legislation, truthfulness, evidence that varies according to the nature of the claims, honesty, fairness, and enabling informed choice.

Useful claims but without any legal definition.

Certain terms—such as "organic," "natural," or "vegan" —are very common on labels, but they have no official definition under European cosmetics regulations. Their use is governed solely by private certification schemes (COSMOS, Ecocert, NATRUE, PETA, V-Label, etc.), whose specifications differ from one another. If no certifying body is clearly identified on the packaging, these claims are the sole responsibility of the brand.

Typology products are certified by the PETA label.

Claims that are prohibited because they are redundant with the law.

Certain claims are explicitly prohibited because they only restate a legal requirement that already applies to all products. This is the case for “not tested on animals”. Since 2013, animal testing has been banned in the European Union for cosmetics, both for ingredients and for finished products. Using this claim would suggest that other products placed on the European market are tested on animals, which is false and constitutes a misleading commercial practice under European law.

Claims permitted subject to supporting evidence.

Other statements are permitted, provided they are supported by evidence documented in the DPP:

• The statement "tested under dermatological control" indicates that a skin tolerance test was carried out under the supervision of a dermatologist. It does not mean that the product is suitable for all skin types, nor that it is hypoallergenic. There is no standardized testing protocol or minimum panel size required by regulations.

• The term "hypoallergenic" may be used provided that the brand can demonstrate that the formulation minimizes, as much as current scientific knowledge allows, the risk of allergic reactions. There is no regulatory European definition of this term, nor any shared threshold. Each brand applies its own criteria—often the exclusion of certain known allergens—without any requirement to disclose them publicly.

  This statement does not mean that a product is free from any risk of allergy, but rather that a formulation effort has been made in this direction, supported by documented evidence included in the Product Information File (PIF).

• The label "non-comedogenic" indicates that a product is formulated to minimize the risk of clogging hair follicles. This claim must be supported by evidence, but the testing methods used (clinical evaluations, self-reported questionnaires) are not harmonized at the European level.

The claims "[substance name]-free," useful when they can be verified.

Claims such as “fragrance-free,” “alcohol-free,” “sulfate-free,” “silicone-free,” or “soap-free” can be directly verified via the INCI list: if the ingredient does not appear there, the claim is factually accurate. These claims are considered acceptable when they provide useful information to the consumer, particularly for reasons related to health, ethics, or specific lifestyles—for example, “fragrance-free” or “alcohol-free” for sensitive/reactive skin, or “sulfate-free” to help preserve hair color.

However, certain limits apply. On the one hand, it is forbidden to disparage a legally authorized ingredient. A “paraben-free” claim that implies that parabens authorized by regulation are dangerous would constitute unjustified denigration of a substance that has been assessed and regulated by European health authorities. On the other hand, non-verifiable claims are contrary to the criteria of Regulation No. 655/2013. This is the case, for example, for “free from endocrine disruptors,” for which there is no officially recognized definition, and for “free from allergens,” which is misleading — any substance can be a potential allergen for a person who is sufficiently sensitized.

• Règlement (CE) n°1223/2009

• Règlement n°655/2013.

• Food and Drug Administration (FDA). Cosmetics labeling guide.