Can I use my existing packaging for the EU Market?

One of the most common recurring questions from manufacturers or distributors looking to enter the European Market, especially in the cosmetics industry, is “Can I use my existing packaging in the EU?”. The answer to this isn’t as straight forward as one might think and must be handled with care to avoid the product (or range of products) in question being removed from the market.

One of the first major blockers, as regards packaging or labeling, that any product entering the EU market might face is the inclusion of imagery or technical jargon that is prohibited inside the EU. Perhaps the most obvious example of this comes in the form of the ‘not tested on animals’ symbol (right). The use of this symbol on the European market is strictly prohibited. This is due to the fact that any form of animal testing in connection with a consumer product is completely banned in Europe, making the necessity for any such labelling imagery void. Products are assumed not to have been tested on animals, so to label one as such can be misleading as it might suggest that other products on the market may have been animal tested.

The most important point for manufacturers and distributors to take away is that all claims on products entering the European Market need to be substantiated. The claims must be supported by testing results produced in a product’s Product Information File (PIF). In addition, a product’s final Precautions for Use must be designated by an appointed Safety Assessor, rather than by the manufacturer themselves.

It is also important to note that instructions for use and all other relevant packaging information must be translated into (at least) the official language of each European country it is being released onto. While this would preferably be done on the labeling or packaging of the product itself, it can also be provided in the form of a leaflet contained within the product’s packaging. Should this be the case, the packaging must affixed with the ‘Refer to Insert’ symbol (right).

All other information required as regards the packaging of cosmetic products in Europe can be found in this useful image:

For more information about European packaging/labeling requirements, to talk to our team of regulatory and legislative experts, or to find more about the compliance process, contact us today.

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