CosmeticOBS - L'Observatoire des cosmétiques
March 20, 2010Learning to read labels

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The Observatory of Cosmetics

In France, many people think that the "e" printed close to the volume/weight figure means "environ" (circa, in English). Indeed, it means exactly the opposite. Nevertheless, this "e" shall not be understood to the gram … Some explanations by Bénédicte Lefranc, a controller in the French General Directorate for Competition Policy, Consumer Affairs and Fraud Control (DGCCRF, as per its French acronym).

Reading time : ~ 6 minutes

Based on the paper given by Bénédicte Lefranc, DGCCRF Controller, in the 10th Meeting on Regulation organized by Cosmed association, held in Marseille on 18 March 2010.

Cosmetics are as food: they shall let the consumer know how much he has to pay for which quantity. As per the European regulation, the nominal content at the time of packaging, given by weight or by volume, shall be displayed on the packaging. This lets the consumer know how much he buys, to the gram, to the millilitre … in principle.

The acceptable error rule

In fact, when the measurement is carried out, things are not that simple. A tolerance is allowed, and endorsed by the regulation. In plain English, one may buy a bit less than what is printed on the label, for the same price (would you have bet it could be another way?), in complete compliance with the law.

To comply with the law, two criteria are to be met:
• The average rule: for a given batch number, the true content shall not be, in average, lower than the nominal content, as printed on labels. A kind of "a bit more, a bit less, as far as the average is exact, everything’s copacetic!".
• The minimum content rule: in a given batch number, no product with a real content less than the nominal content less a "margin for error", depending on the nominal content read on the label, may be sold. For instance, for a 1,000g content, the margin is 1.5%, i.e. 15g: a product weighing 985g complies with the rule. This is acceptable as far as the entire batch has no more than 2.5% of "defective products", i.e. 2.5% of the production under the nominal content.

The exception of small packaging

The only products which shall have at least the nominal content are those with a nominal content of less than 5 grams or 5 millilitres. These may include make-up products (pens, lipstick, eyeshadow…), or high value-added products such as a vial of anti-ageing serum, or a small tube of anti-wrinkles eye contour care …

The nominal content printed on the product is then considered for every package and not as an average figure for the entire batch. Every product with a lower content is then considered as non compliant.

However, printing the weight or the volume when they are lower than 5g or 5 mL respectively is not mandatory. The manufacturer is allowed not to give it. Nevertheless, if the figure is given, the quantity shall be at least the printed figure. Sad to say, but few are the manufacturers who force themselves to do it!

And what about the "e"?

It is very often seen close to the content figure. Some French consumers think of it as a symbol for "environ" (circa), which is not a ridiculous idea, as per what is written just above; others think it comes for a kind of certification ("e" for European), which has nothing to do with the "true weight" of this letter.

The "e" is indeed a guarantee by the manufacturer, which takes responsibility for it, that its products meet all the metrological requirements set up by the regulation (the average figure and the minimum content parameters). It is not mandatory, but for the authorities it is a presumption of conformity, the manufacturer having to carry out its own controls during manufacturing.

"e" = the right weight, for … the right price?

Be aware that not lying, deliberately or not, about the real content of a product does not mean the consumer gets what he paid for.
Indeed, there are other means, not to mislead (what a nasty word!) the consumer, but to make him think he buys more than it seems.

For instance, the product sold under the same name, same reference, with the same price, when, in fact, the content is 20mL less …
Or products sold in large packaging, designed for 50mL jars, but which just contain a 15mL one, set on a large wedge.

Current regulation lets manufacturers free to choose the volume/mass they put in a container; there is no longer a definite figure for every kind of product. The vast range of sizes now marketed does not ease the consumers’ choice.

The only way not to be in a mist is to compare prices for 100mL, or a kilogram, which should be displayed for any product in shops. At least, these figures are understandable!

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