Heed the label: Overcoming compliance challenges

Shifting and varied labelling rules are a major compliance challenge. Nicholas Wallace, Stephenie Overman, Kathryn Wortley, Raghavendra Verma and Jens Kastner report

Regulations affecting what information can, should and cannot be placed on personal care product packaging are among the most demanding of compliance issues facing beauty manufacturers.

One reason is that this is both a very international field and a dynamic one – rules change all the time and vary widely from market to market.

Lost in translation

A good example is a December 2020 ruling at the European Court of Justice (ECJ), where judges ruled that an American cosmetic product sold in Poland unlawfully directed consumers to check a catalogue for information that should have been on the packaging.

An industry leader tells Cosmetics Business this was an unusual attempt to cut corners, but added that shifting European Union (EU) rules on packaging make it increasingly difficult for manufacturers to provide all required information on smaller beauty products.

The case was brought by a Polish beauty salon that had purchased the US-made goods (whose brand was not named in court documents) from an EU distributor. The salon wanted a refund, because the packaging gave no information in Polish as to how the product should be used, which is required by Polish and EU law.

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