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Project service

Cosmetic Product Labeling Review

Your labels and marketing claims checked against the rules in each market, before they cost you a recall or a warning.

Product carton and ingredient panel, studio bench

What the law requires

What is a cosmetic product labeling review?

A cosmetic product labeling review is a document assessment of your label artwork and on-pack text against the labeling rules of every market you sell in. CIGREG checks the mandatory particulars, INCI ingredient list, warnings, language requirements, and claims against Regulation (EC) 1223/2009 Articles 19 and 20, Regulation (EU) 655/2013, the UK Cosmetic Products Enforcement Regulations 2013, the Swiss VKos, and US MoCRA. It is a review of what your label says and how it says it — not a safety assessment of the formulation.

Labels and claims must
List ingredients following INCI conventions.
Carry the mandatory information in the right form.
Make only supportable, lawful claims.
Show warnings in the required language for each market.
Meet the specific rules of each market you sell in.

What this service is

What a cosmetic label review covers

A label fails for small reasons. A missing allergen declaration, an INCI name spelled the way the supplier wrote it, a warning that never made it onto the secondary pack. Each one is a defect a market authority can act on.

Reviewed by Cassandra Maddocks, chemist & biochemist · last reviewed 26 July 2026

A label review checks your artwork against every target market's rules before print: Article 19 particulars and INCI for the EU, the UK RP address for GB, Swiss-language warnings, and the US adverse-event contact. CIGREG reviews labels and claims for $300 per product.

Legal basis: EUR-Lex: Regulation (EC) 1223/2009, FDA: Cosmetics Labeling, Fedlex: Swiss Cosmetics Ordinance (VKos).

The Claims Regulation 655/2013 on EUR-Lex prohibiting authorised-by-authority claims
Common criteria under Regulation (EU) No 655/2013 on EUR-Lex: claims that a product was authorised or approved by an authority are not allowed. Captured 26 July 2026. View the official text.

CIGREG reviews the label as a regulatory document, line by line, against the market you are selling into.

Mandatory particulars

Every market sets a list of particulars that must appear on the container or the outer packaging. The responsible person's name and address, the nominal content, the batch code, the function of the product, the durability date or period-after-opening symbol. CIGREG checks each one is present, correctly formatted, and in the right place.

INCI ingredient list and allergen declarations

The ingredient list is where most labels break. Ingredients must be declared in INCI nomenclature, in descending order of concentration down to 1%, with colourants in any order and ingredients below 1% in any order. Allergens above the declaration threshold must be named. CIGREG checks the list against the formulation data you supply and flags every mismatch.

Warnings, language, and legibility

Warnings must be in the language of the market, and they must be readable. CIGREG checks mandatory warning text, font size where a market sets one, contrast, and whether the text survives the artwork as printed. A warning that is technically present but illegible is not a warning.

Claims

Claims are assessed separately from the label text. CIGREG checks each claim against the common criteria in Regulation (EU) 655/2013 — legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making — and against the evidence you hold.

What you receive: your review report

You receive a written review report: every finding, the rule it breaches, and the correction required. It is a document you can hand to your artwork studio and act on directly.

Claims

Cosmetic claims substantiation: what we assess

A claim is a promise the label makes on your behalf. "Fragrance-free." "Dermatologically tested." "72-hour hydration." Each one needs evidence behind it before it goes to print.

CIGREG assesses claims against the six common criteria in Regulation (EU) 655/2013 and against the substantiation file you hold. Where the evidence does not support the wording, the wording changes — not the other way round.

Claim types we assess

  • Performance claims — hydration, wrinkle reduction, long-wear. These need test data on the finished product, not the raw material.
  • Free-from claims — "free from parabens", "silicone-free". These need a formulation check, and in some markets they are restricted outright.
  • Hypoallergenic and dermatologically tested — these need the test behind them, and the test must be on the product as sold.
  • Natural and organic claims — these need a defined standard. "Natural" has no legal definition in the EU, so the claim must be qualified or dropped.
  • Comparative claims — "better than X". These need a like-for-like comparison and a verifiable basis.
  • Efficacy claims on sun products — SPF and UVA claims sit under their own testing regime and are treated as a separate review.

What substantiation requires

Substantiation means evidence that a competent person could review and accept. Consumer perception studies, instrumental measurements, clinical or in-vitro test reports, or published literature where it applies directly to the finished product. CIGREG tells you which claims your current file supports and which need work before the label is finalised.

By market

Market-specific labeling requirements

The same product, the same artwork, four different rulebooks. A label that clears the EU can fail in the US on the same sentence.

CIGREG reviews against each market separately, because the differences are where the risk sits.

EU

European Union

Labeling sits under Regulation (EC) 1223/2009. Article 19 sets the mandatory particulars and the language rules; Article 20 sets the claim requirements. The responsible person's name and address must appear on the label, and the product must be notified on the CPNP before it is placed on the market.

UK

United Kingdom

The UK Cosmetic Products Enforcement Regulations 2013 govern labeling in Great Britain, with a UK responsible person required for products placed on the GB market. The Windsor Framework governs Northern Ireland, where EU rules continue to apply. CIGREG reviews against both where you sell into both.

CH

Switzerland

Swiss labeling sits under the VKos. Switzerland is not in the EU, so an EU-compliant label is not automatically a Swiss-compliant one. The mandatory information must appear in German, French, or Italian, and the Swiss responsible person must be named.

US

US (MoCRA)

MoCRA changed US cosmetic labeling. The responsible person must be identified on the label, facility registration and product listing apply, and adverse event reporting is mandatory. FDA labeling rules under 21 CFR 701 and 21 CFR 740 set the format, the ingredient declaration, and the required warnings. CIGREG reviews US labels against those rules and against MoCRA's responsible person requirement.

Who does the work

Who carries out the review

Your label is reviewed by a named regulatory specialist, not a queue. The reviewer signs off on the report, and the report carries their name.

Reviews are carried out by Cassandra Maddocks and the CIGREG regulatory team. CIGREG acts as the official Responsible Person for brands selling across the EU, UK, Switzerland, and US markets, so the same team that reviews your label is the team accountable for it in each jurisdiction.

That matters at the point of a market authority query. There is one accountable party, one file, and one answer.

Where this sits
Label and claims review: this service.
Safety report (CPSR): signed by a qualified assessor, separate service.
Product Information File: held for 10 years, separate service.
Notification (CPNP or SCPN): filed by your responsible person, separate service.

What we need from you

How the review works

The review is a document exercise. What you send determines what can be checked, and what is missing determines what cannot.

What you send

  • Final or near-final label artwork, including all panels and the secondary packaging.
  • The full ingredient list with concentrations, or the formulation as supplied by your manufacturer.
  • The intended claims, including any marketing copy that will appear on pack or in the product listing.
  • The markets you intend to sell in.
  • Any test reports or studies you already hold.

What happens next

CIGREG reviews the artwork against each target market, records every finding with the rule it breaches, and returns a written report with the corrections required. Where a claim needs evidence you do not hold, the report says so and names what would support it.

Timing

Turnaround depends on the number of markets and the state of the artwork. A single-market review on final artwork moves faster than a four-market review on draft packaging with unresolved claims. CIGREG confirms the timeline when the inputs are in hand.

Good to have
The product type and how it is used.
Whether the product contacts the eye area or is for children or babies.
Whether any ingredient is a nanomaterial.
The safety assessment, if one already exists.

What you receive: your review report

PASSA written list of findings, each tied to the specific label element or claim.
STATUSA clear pass, fix, or remove status for every claim we assess.
WHYThe reason for each finding, in plain language, with the market it applies to.
FIXSuggested compliant wording where a claim can be reworded rather than dropped.
REMOVEA note of any claim that would need test data, and what kind of evidence supports it.

The report is written to be acted on. Each finding is tied to a specific rule, so your artwork studio can make the change without a second round of interpretation.

Edge cases

Products that need extra care

Some products carry labeling obligations that go beyond the standard particulars. These are the categories where a generic review misses something.

Nanomaterials

Nanomaterials must be declared on the label with the word "nano" in brackets after the ingredient name. The notification and safety data requirements are stricter, and the ingredient must be authorised for its use.

Baby and child products

Products intended for children under three carry specific warning requirements, and the claim set is narrower. Wording that is acceptable on an adult product can be a problem on a product aimed at infants.

Sun and efficacy claims

SPF and UVA claims sit under their own testing and labeling regime. The claim on the pack must match the tested value, and the UVA protection must meet the required ratio. This is a separate review from the standard label check.

Drug-territory claims

A claim that crosses into treating or preventing disease moves the product out of cosmetic territory. That is a classification question with labeling consequences, and it is better answered before the artwork is printed.

FAQ

Frequently asked questions

A cosmetic product labeling review is an assessment of your label artwork and on-pack text against the labeling rules of each market you sell in. CIGREG checks the mandatory particulars, the INCI ingredient list, allergen declarations, warnings, language, and claims against Regulation (EC) 1223/2009 Articles 19 and 20, Regulation (EU) 655/2013, the UK Cosmetic Products Enforcement Regulations 2013, the Swiss VKos, and US MoCRA. It reviews what the label says, not whether the formulation is safe.

No. A label review is a document review of the artwork and the claims. A safety assessment — the Cosmetic Product Safety Report — is a separate assessment of the formulation and its toxicological profile. CIGREG carries out both, and they are separate deliverables with separate sign-off.

CIGREG reviews labels for the EU, the UK, Switzerland, and the US. Each market is reviewed against its own rules: Regulation (EC) 1223/2009 for the EU, the UK Cosmetic Products Enforcement Regulations 2013 for Great Britain, the VKos for Switzerland, and MoCRA plus FDA labeling rules for the US. A single review can cover all four.

CIGREG needs your label artwork including all panels and secondary packaging, the full ingredient list with concentrations, the claims you intend to make, and the markets you are selling into. If you already hold test reports or studies, send those too. The more of the file that is complete, the more of the label can be cleared in one pass.

Yes. CIGREG checks the ingredient list against the formulation data you supply, confirms INCI nomenclature, verifies the descending order of concentration, and checks that allergens above the declaration threshold are named. Ingredient list errors are the most common defect found on cosmetic labels, and they are the first thing a market authority reads.

Yes. CIGREG assesses claims against the six common criteria in Regulation (EU) 655/2013 — legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. Where a claim is not supported by the evidence you hold, CIGREG tells you what would support it or how to reword it.

Reviews are carried out by Cassandra Maddocks and the CIGREG regulatory team, and the report carries the reviewer's name. CIGREG acts as the official Responsible Person for brands selling across the EU, UK, Switzerland, and US markets, so the reviewing team is also the accountable party in each jurisdiction.

You get a written finding, the rule it breaches, and the correction required. CIGREG does not leave you to interpret the regulation — the report is written so your artwork studio can act on it directly. Where a claim needs evidence you do not hold, the report names what would substantiate it.

Pricing

Fixed, transparent pricing.

A label and claims review per product, at a single published rate.

Label and claims review, per product $300

Prices in USD, per product.

See full pricing →

Need your labels and claims checked?

Tell us your products and markets and we will quote your review at a fixed price.

In practice

Compliance, in the real world.

Ingredient panel and carton on a studio benchA label proof being marked upINCI list checked against a formula