National Requirements for Placing Cosmetics on the German Market
In Germany, cosmetic products are regulated by the EU Cosmetics Regulation and the “Verordnung über kosmetische Mittel” (Regulation on Cosmetic Products). While the EU provides a harmonized framework, there are additional national requirements in Germany for certain aspects that are not harmonized across the European Union. In this post, we will review the key rules and regulations to keep in mind when placing cosmetics on the German market.
Notification and Labelling Requirements for the German Market
Germany imposes specific requirements for cosmetic products, particularly when Germany is the first EU country of import from a third country. These requirements include:
- Product Sample Labelling:
Samples in Germany must be clearly labelled with phrases like:- “Unverkäufliches Muster, nicht zum Verkauf bestimmt” (Free sample – not for sale)
- “Nicht zum individuellen Verkauf” (Not for individual sale)
This ensures that consumers understand the product is for sample purposes only and not available for sale.
- Manufacturer Location Notification:
Verordnung über kosmetische Mittel requires cosmetic companies based in Germany to notify market surveillance authorities about the place where the products are manufactured or the location within the EU where products are imported from (Article 3). - Labelling of Unpacked Products:
Unpacked products must follow the same labelling requirements as packed products. If this is not possible for practical reasons, the required information should be displayed on a label near the product or its container (Article 5).
Other Applicable Laws for Cosmetics in Germany
In addition to the EU Cosmetics Regulation, there are other important national laws to consider when placing cosmetics on the market in Germany:
- LFGB (Food, Commodities, and Feed Code):
Articles 26–29 contain provisions on prohibitions and authorizations to protect health and prevent consumer deception. - Measuring and Calibration Act (MessEG):
This law regulates the correct labelling of the nominal filling quantity for prepackaged products. - Regulation on Protection Against Hazardous Substances:
This regulation applies to the shipment of raw materials and cosmetics that may involve hazardous substances. - Aerosol Packaging Regulation:
This law regulates the labelling and safety requirements for aerosol packaging with a capacity of 50ml or more.
Conclusion and Compliance
When placing cosmetic products on the German market, it’s essential to comply with both the EU Cosmetics Regulation and Germany’s national regulations. Ensuring compliance not only protects consumer safety but also guarantees that products meet legal standards.
For the latest updates, check the official website of the competent German authority.