Digital labelling for cosmetic products

March 27, 2023 – The EU law requires certain elements to appear on the labelling of cosmetic products to give consumers essential information. For example, the individual labelling of some allergens when they exceed specific concentrations allows consumers to avoid the substances they have been sensitized to.

Nowadays, we face divergent interests when it comes to labelling of cosmetic products. On one side, according to the EU Chemicals Strategy for Sustainability, cosmetic products will have to bear additional information about hazardous chemicals. Moreover, consumers want to know more about the products they purchase, particularly in terms of substances, their origin, and their environmental impact. On the other hand, beauty brands aim at reducing packaging for ecological reasons.

Hence, in the context of the revision of the EU Cosmetics Regulation, the European Commission is considering the introduction of digital labelling for cosmetic products. It will need to be used voluntary or mandatory. Nevertheless, in both cases, essential elements will have to continue to appear on the packaging. The European Commission is currently discussing the topic and will likely publish its proposal for revision in the summer of 2023.

Pros and cons of digital labelling

From the contributions to the public consultation on the revision of the EU Cosmetics Regulation, it emerged that digital labelling is considered to have many advantages:

Consumers can access additional information in an easily legible format to make more informed choices at the time of purchase;
Beauty brands will not have to print new labels and destroy old ones every time there are regulatory updates or changes to the product. Hence, digital labelling will reduce the connected cost and environmental impact;
Online searches can facilitate cosmetovigilance activities.

At the same time, digital labelling has some disadvantages. The European Commission must consider those in the revision of the EU Cosmetics Regulation:

Not everyone has access to the Internet, and especially older people are less confident in using digital tools. However, the EU institutions must ensure that all consumers are informed about essential safety data about cosmetic products;
The implementation of digital labelling, even if voluntary and on top of the on-pack labelling, will require the industry and authorities some time to adapt. Therefore, a transition period would be necessary.

NATRUE survey on consumers’ perception

Considering the possible adoption of digital labelling for cosmetic products, several independent organisations and the EU institutions conducted studies to investigate the perceptions and expectations of citizens and stakeholders.

In light of this, at the beginning of 2022, NATRUE commissioned a survey on digital labelling. It involved more than 1000 people from Germany and France. NATRUE is an association that aims to promote natural and organic cosmetic products in the EU and worldwide.

The results of the survey show that the majority of consumers would prefer to have the information on the pack (44% in Germany and 37% in France) but with additional details available digitally (49% and 57%, respectively).

Furthermore, respondents identified a QR code as the preferred tool to access digital information.

You can check the other topics under discussion for the revision of the EU Cosmetics Regulation here.

Lastly, you can find an overview of mandatory labelling requirements for cosmetic products in our previous articles: part 1 and part 2.