A skincare carton may sound simple until one line is a legal precaution and the next is a brand promise. They cannot be edited by the same rules.
In brief
- Under Article 19(5) of Regulation (EC) No 1223/2009, the language of specified label information is determined by the law of the Member State where the product is made available to the end user.
- The ingredient list uses the nomenclature required by the Regulation, and the product information file must be in a language easily understood by the competent authority.
- Approved claims and legal precautions follow different editing rules from optional brand copy.
What the cosmetics Regulation makes local
Regulation (EC) No 1223/2009 governs cosmetic products placed on the EU market. Article 19 lists the information on the container and packaging, including responsible-person details, nominal content, durability, particular precautions, batch number, function and ingredients, subject to the article’s conditions.
Under Article 19(5), the language of specified information—such as nominal content, durability, precautions and function, as well as certain alternative ways of providing it—is determined by the law of the Member State where the product is made available to the end user.
That does not mean translating every ingredient name as marketing copy. The ingredient list uses the nomenclature required by the Regulation.
Article 11(3) requires the product information file to be available in a language easily understood by the competent authority of the Member State where it is kept. These are different audiences and different language decisions.
Protect both the claim and the caution
A face cream may combine an evocative front-of-pack line, a precise use precaution, an ingredient list and a digital campaign. A claim such as “24-hour hydration” needs evidence and must be treated consistently across markets; Article 20 prohibits claims implying characteristics or functions that the product does not have.
The responsible person approves what can be said. A copywriter may localize the tone, but cannot quietly change the scope of the approved claim.
In practice, pack size, folding cartons and small containers complicate multilingual production. Article 19 provides specific solutions where information cannot practically appear on the label, but the regulatory owner must determine when those routes apply. The translated text still needs an artwork review in its final location.
A cosmetics language brief
- Separate text types: mandatory particulars, ingredients, approved claims and optional brand copy.
- Confirm markets: national language requirements and product classification before layout.
- Lock approved claims: supply substantiation and any prohibited or limited wording.
- Review the package: read the carton, container, leaflet and online text together.
- Manage change: link each language to formula, artwork and product information file revision.
The strongest local version keeps the brand appealing while making the product’s legally significant information easy to find and faithful to its evidence.
Related reading: our skincare & dermocosmetics language services and EU packaging rules: the multilingual information behind a market launch. For official background, see the European Commission’s cosmetics pages ↗ and its cosmetic ingredient database (CosIng) ↗.
Primary legal text: Regulation (EC) No 1223/2009 ↗ (Articles 11(3), 19 and 20). Further reading: European Commission: Cosmetics ↗, Cosmetic ingredient database (CosIng) ↗. This article explains selected language provisions and does not replace a product-specific regulatory assessment.