Many people are confused by the language requirements in the EU. Although this aspect falls under the responsibility of your distributors (according to Article 6 of the EU Cosmetics Regulation), it is important to make a reminder of the rules currently in application as the design and edition of labels and packaging is a costly exercise for cosmetic brand owners.
According to Article 19 §5 of the EU Cosmetics Regulation, distributors have to ensure that a certain number of labeling requirements are properly translated in the national language(s) of the countries where the products are intended to be sold. These labeling requirements are:
- The nominal content
- The date of minimum durability and the Period After Opening (PAO)
- The warnings, precautionary use statements
- The function of the cosmetic product
- The enclosed or attached leaflet, label, tape, tag or card if there is one
- The notice in immediate proximity to the container in which the cosmetic product is exposed for sale if any
The distributors are fully entitled to refuse products that would not comply with these language requirements and such a rejection cannot be regarded as the responsibility of any EU Responsible Persons.
The labeling of the product function is not mandatory if this one is clear from the product presentation. However, if you have to (or decide to) label it, then it has to be in the appropriate language(s). Having the product function in English and the translations in a leaflet is not acceptable unless the product is only sold in Cyprus, Ireland, Malta and United Kingdom.
Likewise, the warnings and precautionary use statements can be reported on the leaflet if there is no space enough on the container (primary packaging) or the packaging (secondary packaging). However, if you have to label them, then it has to be in the appropriate language(s). Again, having the warnings and precautionary use statements reported in English on the container or packaging and the translations in a leaflet is not acceptable unless the product is only sold in Cyprus, Ireland, Malta and, United Kingdom.
On this basis, brand owners basically have three options:
- Develop a specific label and packaging for every country (or for a couple of countries) –BIORIUS’ recommendation
- Create a unique label and packaging complying with all the language requirements (all the translations are labeled on the container or packaging) – impossible unless you only target a few countries of the EU
- Develop a unique label and packaging and apply a sticker where needed – practical option but questionable from a marketing standpoint
As reference, the national languages to consider are the following:
|Belgium||Dutch and French and German|
|Cyprus||Greek or English|
|Finland||Finnish and Swedish|
|Luxemburg||French or German or Luxemburgish|
|Malta||Maltese or English|
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