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|
Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products
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23 Responses to “EU Regulatory Update: A Brief Reminder of Language Requirements”
I would like to know if there has to be a language Abbreviation before starting with the text? For example: DE before the German text or IT before the Italian text?
This is not an EU legal requirement and, to the best of my knowledge, no EU Membre States enforced such an obligation. I admit that this may be convenient for the consumers but this is not mandatory.
I would like to know if there are special requirements for translation of the front of the product and the name of the product. Especially in concern to the French market where I hear that it is mandatory to write the name of the product in French on the front.
Dear M. Rasmussen,
I am sorry for the late reply.
The European legislation does not oblige you to translate more elements than the ones reported in my article. However, there is some room for interpretation and, indeed, some countries like France are used to requiring a translation of the product name in some circumstances.
Indeed, Article 19 §1 (f) indicates that “the function of the cosmetic product, unless it is clear from its presentation;”. So, it is not mandatory to explicit the function of the product if the presentation of your product makes it obvious. However, if the function is reported (regardless of wether or not this is required), then, you have to translate it properly (as required by Article 19 §5).
Sometimes, the function is included in the product name. This is why its translation is required while the product name does not have to be translated per se.
E.g. In France, the product name “Wonderful Lips – Priming Gloss Stain” would have to be translated as “Wonderful Lips – Rouge à lèvre liquide / Priming Gloss Stain – Aspect Brillant”.
I hope that it helps.
Regarding sales of goods in EU:
Does it mean, that we can leave ingredients, name and address of manufacturer, country of origin, etc. in English language on the package?
We just need to translate the warnings, precautions (German for Germany, French for France, etc.)?
Indeed, the legislation does not say anything about the name and address of the Responsible Person or the country of origin. However – and I realize that I forgot to cover this point in my article – be careful with the claims. Indeed, an other piece of legislation (EU No 655/2013) regulates the cosmetic claims via the so-called ‘common criteria’. One of them is ‘legal compliance’ and notably says:
‘The acceptability of a claim shall be based on the perception of the average end user of a cosmetic product, who is reasonably well-informed and reasonably observant and circumspect, taking into account social, cultural and linguistic factors in the market in question.’
It also says under the criteria ‘Informed decision making’:
‘Claims shall be clear and understandable to the average end user.’
Based on these elements, the Authorities of an EU country may oblige you to get the claims translated in the national language.
Hope that it helps.
Hello, very useful article, thank you.
I have a question.
If I put English language on the packaging, name with the function + description of the product (what it does) + how to use it and place it in front of the packaging.
Can I put those above information on the bottom of the packaging in other language? A I intend to sell in 2 countries and don’t want to overcrowded the front of the packaging.
Or all these information has to be placed in front together like in English + other language? And other language cannot be placed on the bottom but together with English.
Thank you very much for your help.
We suggest you work with the government agencies in the countries in question to ensure your packaging meets their labeling requirements. Our articles provide information, not legal advice.
Thank you for your positive feedback. As Angie mentioned these articles simply provide information and I cannot answer this specific question here.
Having said that your question is important and it seems that you need assistance. So, to complete Angie’s reply, I would suggest that you contact a consulting company specialized in this field. Biorius is a possibility but there are others.
Thanks so much for this finally slightly clarifying article!
Could you possible answer two more questions for me?
1. Precautions and how to use: I did not fully understand your argumentation there. In a nutshell, if we are compelled by EU law to put on precautionary warnings and how to use instructions, we have to do so in the official language of the member state we’re selling in too?
There’s no way we can include the how to use instructions in the member state’s language in a leaflet?
2. Ingredients: As long as the ingredients are posted according to INCI standards they do not have to be translated?
And not to forget, could you possibly give an example what you mean here?
1. The enclosed or attached leaflet, label, tape, tag or card if there is one
2. The notice in immediate proximity to the container in which the cosmetic product is exposed for sale if any
Also, how do I find the authorities responsible in the respective member countries?
Thanks so much!
for countries such as Croatia, Bosnia, Ukrania
whats lenguages ?
Croatia is now a Member State of the EU. Therefore the same legislation applies. However the national langue is Croatian. Bosnia and The Ukraine are not members of the EU and apply different pieces of legislation. In those countries, it is highly recommended that everything be translated in respectively Bosnian, Croatian, Serbian in Bosnia and in Ukrainian in The Ukraine.
I have read your article but would still like clear clarification if possible please? Is it mandatory to have a German translation for products that already have English and French on to be sold in Germany?
Please let me know, thanks.
From a marketing standpoint, we always recommend that the translations are as exhaustive as possible. The best way to touch consumers is to speak their language (literally).
From a regulatory standpoint, there are numbers of elements that you absolutely have to translate (see above). It is strongly recommended that the claims are also translated.
Hi. I have always seen cosmetic products sold throughout the EU to be translated in french other than main languague English. How do they do that if each country has to have their own languague? How do we manage the stocks by having one product in German, one in Italy, one in France where all of these countries do understand French?
Im planning to sell in Germany, France, Netherlands and Italy. I have only got it translated in French and English. Do i need to change all?
Sam – you should see the labels in Switzerland! 4 languages – written very small. But since we are not in the EU, I asked and found that we must use at least one of the national languages and then the other can be English. But, to reach the most customers German, French, Italian and English are preferred. If you add German to your product labels you would be adapted well to Switzerland!
Where can I find the product description in all the main languages? (i.e. Shower Gel, Body Lotion, Shampoo, Conditioner, Dry oil). Is there a source?
one question that is always confusing.
Cosmetic products with both primary and secondary packaging:
If the primary packaging is too small to carry all the warnings (e.g. 3 languages on the label), can the ”hand-in-book” symbol be used to refer to the information on the secondary packaging/label?
Thank you for the information. I do not know it. ¡¡Tank you very much!!
I am wondering about label requirements in Latvia specifically for cosmetics.
Is there any additional information needing translation on the label, other than the EU requirements stated in this article? (i.e. is the “How To Use” an extra requirement in Latvia?)
I have a semi permanent hair dye which will be sold worldwide. There is a label on the bottle and also has a carton. Does all the information have to go on the label and the carton? And if being sold worldwide is the 9 primary languages acceptable?
I actually have the same question.
Looking at the regulation, I assume it’s actually possible.
Did you find an answer?