A general trend is to understand the mentions on a label in a comprehensive manner, and to give them a meaning that is driven by common sense. This may be misleading, or may lead to not “feeling” the “subtleties” allowed by the regulation. This is the case with the “Made in." Explanations.
As for everybody coming with a brain in an operational state, you translate the "Made in France” mention by …”Made in France” …and your understanding is that the product so labelled has been manufactured in France, even that it has been completely manufactured in France.
Not that easy! Customs and regulation of the cosmetic world may put at risk a so logical interpretation.
Made in …several countries
Indeed, it is usual that a product contains ingredients from different countries: Argan oil from Morocco, shea butter from Burkina Faso, rose from Turkey, a solvent from Russia, glycerin produced in China or Estonia …
Further, a frequent occurrence is that the product has been designed in the Research and development Department of a French manufacturer, that the blend of ingredients is made in Taiwan, that bottling is made in Italy, in Belgium or in a Paris suburb, that the cardboard is printed in Romania or elsewhere …
Then, how shall the “Made in” be determined?
The Community Customs Code gives the answer, with the concept of “substantial transformation," that shall be understood as the most significant step in the manufacturing process of the finished product.
A cosmetic, therefore, is “Made in” …the area where the product that, at the end, the consumer applies on his skin, is physically manufactured.
Made in …explicit
Beware: displaying an Eiffel Tower picture or a tricolor (blue, white, red) flag on the packaging of a cosmetic is not enough to make it a “Made in France” product.
The mention alone, explicit and written in full, shall prevail.
A too much important display of significant signs (visuals, logos or others) of a country when the product is manufactured elsewhere can even be sanctioned during a check by Customs officers.
Made in …EU
This mention can be seen, sometimes, meaning “manufactured in the European Union” on some labels. Not that informative, isn’t ’it?
Indeed, this is due because some manufacturers are reluctant to label their products as “Made in a-country-not-that-glamour”, or “in a-country-that-may-be-not-trusted-for-the-safety-of-its-manufacturing-processes” …When they cannot use the “Made in France” label, so “noble” and “sales-helper”, they may prefer such a “fuzzy” mention that could benefit their product.
This method comes with its own limitations. First, the consumer is not always a buyer who does not think. Further, this mention is not allowed outside of the EU …the other countries wanting that only a country of origin be mentioned, and not a very large community of States.
Therefore, why is it sometimes found on the …European market? The answer comes underneath!
Made in …nowhere
While the “Made in EU” mention is, to say the least, what about the products without any mention of origin?
Even if they do not let us know where they come from, nevertheless, they are compliant with the regulation …as far as they are manufactured and available only on the European market.
Why this legal silence? Explanations.
Keep in mind that the European regulation on cosmetics is the same all over Europe, and is applied with the same criteria in all the countries of the Union. The manufacturers shall meet the same requirements for the safety of ingredients and formulae, about the Good Manufacturing Practice, etc.
Making it mandatory to mention a “Made in” mention in this regulatory frame could be seen as a “flag” that consumers could interpret in a positive manner (Made in France!), or sometimes, in a very negative manner (…please, accept that the CosmeticOBS-L’Observatoire des Cosmétiques Editor gives no example for this case, as regular readers of our website live in many countries!) After the regulation, all the products are supposed to be on the same level of quality, whatever the country of origin …
This explains why the “Made in EU” or no “Made in” at all are accepted in Europe …but are not acceptable beyond the Union borders.
To know more
and to know how to determine which “Made in” mention to use, after which criteria
• Go to the article “ The mark of origin ” in the Professional (PRO) section of the CosmeticOBS-L’Observatoire des Cosmétiques.