As every year, at the end of the Cosmetic Valley Perfumes & Cosmetics Congress held on 23 and 24 November 2022, the FEBEA team answered questions prepared by congress participants during the two days of conferences. Focus on issues related to labelling, claims and obligations of the Responsible Person.
Labelling
Question
In the context of the revision of the Cosmetics Regulation and digital labelling, will the INCI list remain mandatory on the pack or can it be fully digitised?
Laure Menanteau’s answer
It is hoped that DG Grow will propose digitisation of the list of ingredients. But the position of the French authorities is that everything must remain on the pack, and that if there is digitalisation, it can only be complementary and cannot replace the information on the packaging.
Question
In the context of products reconstituted by the consumer, what would be the mandatory information to be added on the reconstitution container? Which INCI list should be chosen: before or after reconstitution?
Laure Menanteau’s answer
For a solid product, which will be reconstituted, it is necessary to provide for labelling with an INCI list that does not contain water, since the list of ingredients of the product being sold must be labelled. And on the bottle in which the dilution is going to be made, you have to label all the compulsory information required by Article 19 of the Cosmetics Regulation. It’s better if you supply the bottle, so that you can control it, particularly in terms of …
