Cosmetic Label Function: When You Must State the Product Function

Most founders know that a cosmetic label needs the ingredients, the batch number and the responsible person. One item gets overlooked more often than any other: the cosmetic label function, meaning the statement of what the product is for. Sometimes you can skip it, and sometimes leaving it out makes the label non-compliant. This guide explains the rule in plain language, shows when the function is “clear from the presentation”, how to word it and how it connects to your claims and your safety file. It is general information, not legal advice. In the EU, the function of the product must appear on the label unless it is clear from the way the product is presented, so a fantasy name or an unusual format almost always needs a function statement.

The short answer

Article 19 of Regulation (EC) No 1223/2009 lists the information that has to be on the container and packaging of a cosmetic product. One item is the function of the product, “unless it is clear from its presentation”. The simplest safe approach is to state the function whenever there is any doubt: a name such as “Shampoo” or “Hand cream” may stand on its own, whereas “Velvet Touch” or “Glow Ritual” needs words like “Brightening face serum” next to it. Great Britain’s retained version of the Regulation contains the same requirement.

What exactly does the law require?

Besides the function, Article 19(1) asks for the name and address of the responsible person, the nominal content, the minimum durability date or the period-after-opening symbol, precautions for use, the batch number and the list of ingredients. For the function, the Regulation gives you an exemption, not a free choice: you may leave it out only when a consumer would understand what the product is just by looking at it. The wording is deliberately short, and the Regulation does not provide a list of products that qualify, so the judgement is yours and, in a dispute, a market surveillance authority’s.

Read also How to Label Small Cosmetic Containers and Samples

What does “clear from its presentation” mean?

Presentation covers the product name, the packaging shape, pictures and all text on the pack, as well as how it is displayed. The function is clear when an ordinary consumer, seeing the product as sold, would have no real doubt about it. Typical cases:

• Usually clear: a tube labelled “Toothpaste”, a bottle with “Shampoo” in the product name, a lipstick in an unmistakable lipstick format.
• Often unclear: an unlabelled pot or jar, a dropper bottle called “Serum”, a stick or roll-on with a brand name only.
• Not clear: a fantasy or brand-style name, an unusual product format, or a product that could be several things, such as a balm, an oil or a mist.

Authorities and national guidance can differ on borderline cases, so if you sell in several countries, take the strictest view for your packaging.

How to word the function

Good function statements are short, factual and use the product type plus the purpose. Examples:

• “Moisturising face cream”
• “Cleansing shower gel”
• “Perfumed body mist”
• “Protective lip balm”
• “Hair conditioner for dry hair”

The Regulation defines cosmetic products by their purposes: cleaning, perfuming, changing appearance, protecting, keeping in good condition or correcting body odours. A function statement within this range is safe. Avoid vague words such as “treatment” or “therapy” and any wording that sounds like a medicine.

In which language must it appear?

The language of the function statement, as for the precautions and the durability information, is decided by each Member State where the product is made available to the consumer. In practice this usually means the official language of that country, though some countries accept additional languages or symbols. Check the rules of every market you sell in. If you sell across borders, a multilingual label or a separate version for each market is the usual solution, and the same space limits that apply to ingredients and warnings apply to function text.

Read also EU Cosmetic Label Requirements: Complete Checklist

Where on the pack must it appear?

The function belongs on the container and on the outer packaging where there is one. The Regulation lets you place the precautions and the ingredient list on an enclosed leaflet, label, tape, tag or card when that is impossible for practical reasons, but that exception does not extend to the function. A product in a small tube with no space should still carry a short function wording, for example “Lip balm”, directly on the tube or its box.

Function and claims are not the same thing

A function statement says what the product is. A claim says what the product does or promises. “Face cream” is a function. “Reduces wrinkles in two weeks” is a claim and needs evidence under Regulation (EU) 655/2013. Some words are both: “moisturising” works as a function description and as a claim. If you include it, be ready to support it with data. A function statement should never carry a claim you cannot prove or an implication of medical effect.

Borderline products and medicinal wording

If your function statement describes treating or preventing disease, the product moves towards the medicinal product or medical device category, where different law applies. Wordings such as “eczema cream”, “antibacterial gel” or “anti-inflammatory serum” are classic red flags. Rephrase the function in cosmetic terms, such as “Moisturising cream for dry skin”. If the product truly has another purpose, the product category and the safety file must reflect that.

Read also Cosmetic Label Warnings: Mandatory Precautions Explained

Multi-function products, sets and small packs

• Multi-function products: state the main function and, where helpful, the secondary one, such as “Tinted moisturiser with sun protection”. Each function mentioned needs to be true and supported.
• Sets and gift boxes: each item that is sold or used on its own carries its own labelling.
• Samples and minis: the batch and content details can have relaxed rules for very small items, but function is not part of those exceptions in general, so plan the space.
• Refills: label them in the same way as the original product, and remember that a refill pouch is different packaging that may need its own stability and compatibility test.

Keep the function consistent across your documents

The function on the label should match the intended use in your product information file, the product category in the CPNP notification and the description in the CPSR. Your safety assessor judges exposure on the basis of the intended use, so a leave-on face serum and a rinse-off cleanser are assessed differently. If you change the function on the pack later, tell your assessor so the file is updated.

Label function checklist

1. Look at the product as a consumer sees it: name, shape, pictures, text.
2. If any doubt remains, add a function statement in the language of each market.
3. Use plain, cosmetic wording from the list of recognised purposes.
4. Check that every word in the statement is supported by evidence, for example patch test data for “suitable for sensitive skin”.
5. Keep the function consistent with the CPSR and the CPNP entry.
6. Check the pack proof before printing and keep the approved artwork in your file.

Frequently asked questions

Is the function mandatory on every cosmetic label?

It is mandatory unless it is clear from the presentation. When in doubt, include it.

Can the function be on a leaflet instead of the pack?

The leaflet option in the Regulation covers precautions and ingredients, not the function, so place the function on the pack itself.

Does the function need to be translated?

The language is set by each Member State where the product is sold, so check the rules of your target markets.

Key takeaways

• The function of the product must be on the label unless it is clear from the presentation.
• Fantasy names and unusual formats nearly always need a function statement.
• Use plain cosmetic wording and avoid medicinal terms.
• Keep the function consistent across the label, the CPNP entry and the CPSR.