November 29, 2021 – Christmas season is approaching, and among the most popular products, are the beauty advent calendars and cosmetic gift boxes: a collection of cosmetics sold together in a single package.
This article will guide you on how to notify and label them comply with the EU Cosmetics regulatory framework.
Is it a cosmetic kit?
Firstly, it is essential to highlight the difference between a cosmetic kit and a mere marketing/commercial kit. There is no definition of a cosmetic kit in the EU Cosmetics Regulation. Still, it is generally identified as a multi-component product – i.e., a cosmetic made of several separate elements that, by their nature, must be used together – as a mix or sequentially. For instance, hair dye sets and skin peeling kits.
A cosmetic kit must be notified on the CPNP with a specific procedure, and the single components cannot be placed on the market separately.
However, beauty brands often choose to sell several cosmetics together – as for example, a main package that contains both a shampoo and a conditioner. These are not cosmetic (procedural) kits but mere marketing kits. The decision to sell a product in this form depends solely on the commercial choices and not on regulatory requirements. Hence, all the cosmetics within the box must be individually notified and could be sold as stand-alone products.
Considering the above, it is evident that beauty advent calendars are not cosmetic kits but marketing kits. Therefore,
- All the cosmetics included must be notified separately on the CPNP before being placed on the EU market;
- The labels must be compliant with the requirements foreseen in the EU Cosmetics Regulation. In this context, the primary calendar box is the outer packaging, while the label attached to the products inside is the inner packaging.
How to label a beauty advent calendar?
According to Article 19 of the EU Cosmetics Regulation, for a marketing kit to be compliant, the following elements must appear on the labels of each product (the so-called inner packaging):
- Brand Name;
- Cosmetic function;
- Responsible person details;
- Country of origin;
- Expiration date or PAO;
- Batch number.
Generally, cosmetics included in an advent calendar are of small size, so the nominal quantity does not have to be specified if it is less than 5 ml or gr. Moreover, due to space limits, the list of ingredients can be omitted from the inner packaging. The warnings can be written on an enclosed leaflet or the outer packaging, provided that the symbol ‘refer to insert’ (commonly known as the ‘open book’ symbol) is affixed to the product.
On the other hand, the box (outer packaging) must display all the information mentioned above for each cosmetic product – including the ingredient list and precautions for use.
Lastly, the national language requirements – translations to the users’ language – must be met.
Are you planning to place a beauty advent calendar on the EU market? Do you want to know more about cosmetic kits? Contact us today and subscribe to COSlaw.eu to access all articles on the EU cosmetics regulatory framework and more!
- European Commission. (2020). Manual of the Working Group on Cosmetic Products (Sub-group on Borderline Products) on the scope of application of the Cosmetics Regulation (EC) No. 1223/2009 (Art.2(1)(a)). Retrieved on 17/11/2021 from https://ec.europa.eu/docsroom/documents/42850
- European Commission. (2017). Guide to Using CPNP Cosmetic Products Notification Portal for Responsible Person and Distributors. Retrieved on 17/11/2021 from https://ec.europa.eu/growth/sectors/cosmetics/cosmetic-product-notification-portal_en
- Cosmetics Europe. (2011). Cosmetics Europe: Guidelines on Cosmetic Product Labelling. Retrieved on 17/11/2021 from https://cosmeticseurope.eu/files/8814/6407/5369/Guidelines_on_Cosmetic_Product_Labelling_-_2011.pdf
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