Sample report · EU cosmetics
EU cosmetic label check: a sample report
A real RegaaS review of a demo sunscreen spray label, front and back, run against EU cosmetics rules. It is what a check before print returns: each issue marked on the artwork, the regulation behind it and the change to make.
- Product:
- RegaaS babies&kids SENSITIV SCHUTZ
- Market and product type:
- EU - Cosmetic
- Uploaded:
- 2 PNG images: the front and the back
- Reviewed:
- October 13, 2026
1,976
rules considered
19
potential risks
101
points to verify
219
requirements met
The rules that did not apply to this product were set aside. A potential risk is something on the label that conflicts with a rule; a point to verify is a requirement the label alone cannot settle.
The label is a demo made for illustration. The brand is RegaaS's own, and the numbers printed on it are placeholders, which the review flagged as finding 6.
The marked-up label
Numbered boxes show where each potential risk appears on the artwork. The numbers match the findings below.
Findings
The issues the review flagged, grouped. Each shows what the label says now, the change to make, and the rules cited.
- 1
The “Free of Octocrylen / Fragrance-free” claim contradicts the ingredient list
The label makes multiple claims of “Does not contain UV filter Octocrylen” and “Parfümfrei (fragrance-free)”, but the ingredient list (Ingredients) on the back clearly lists Octocrylene, Parfum, and multiple fragrance allergens. The claims directly contradict the actual ingredients, constituting a false claim.
Before: on the label
Front claim: “Frei von den UV-Filtern Octinoxat, Oxybenzon, Octocrylen und frei von Mikroplastik.”; yet the back ingredient list (Ingredients) includes “Octocrylene”; and the label claims “Parfümfrei” while the ingredient list includes “Parfum, Alpha-Isomethyl Ionone, Limonene, Linalool, Citronellol”
The label claims “Parfümfrei” and “Frei von... Octocrylen”, but the ingredient list contains “Parfum” and “Octocrylene”
After: the change to make
Verify whether the formulation contains Octocrylene and Parfum; if the formulation indeed contains them, claims such as “Frei von...Octocrylen” and “Parfümfrei” should be removed, or the formulation should be adjusted to align with the claims, ensuring that the label content is truthful and does not mislead consumers (especially as this product claims to be suitable for infants, young children, and sensitive skin).
Rules cited
- DIRECTIVE 2005/29/EC p. 7
- DIRECTIVE 2005/29/EC p. 6
- Technical document on cosmetic claims p. 4
- Technical document on cosmetic claims p. 12
- Technical document on cosmetic claims p. 13
- REGULATION (EC) No 1223/2009 p. 10
- REGULATION (EC) No 1223/2009 p. 16
- REGULATION (EU) No 655/2013 p. 3
- 2
Specific chemical ingredients lack aquatic toxicity hazard labeling (H413).
The product contains Diethylamino Hydroxybenzoyl Hexyl Benzoate and Ethylhexyl Triazone, which according to regulations should be labeled with H413 (May cause long lasting harmful effects to aquatic life), but this hazard warning is not found on the label.
Before: on the label
Ingredients: ... Diethylamino Hydroxybenzoyl Hexyl Benzoate ...
Ingredients: ... Ethylhexyl Triazone ...
After: the change to make
Add H413 hazard warning statements to the label or relevant safety data documents, covering the above two ingredients.
Rules cited
- REGULATION (EC) No 790/2009 p. 191
- REGULATION (EC) No 1272/2008 p. 583
- 3
The “Kinderärztlich bestätigt*” claim lacks corresponding explanatory notes
The front of the label marks the claim “Confirmed by pediatricians” with an asterisk, but no supplementary explanation or substantiating evidence corresponding to the asterisk is found throughout the label, leaving consumers unable to know the specific basis for the claim.
Before: on the label
★ Kinderärztlich bestätigt*
After: the change to make
Supplement the label with specific explanatory text corresponding to the asterisk (such as test methodology, sample size, or evaluation criteria), or remove the claim.
Rules cited
- REGULATION (EU) No 655/2013 p. 4
- 4
The “Mit Bio-Kamille” claim is not found in the ingredient list, involving false claims and efficacy extrapolation
The front of the product claims to contain organic chamomile (Mit Bio-Kamille) and lists it under the skin tolerance section implying soothing efficacy; however, the ingredients list (Ingredients) does not include any chamomile-related INCI ingredients, indicating that the claim does not match the actual formulation.
Before: on the label
• Mit Bio-Kamille and Ingredients: Aqua, Alcohol Denat., Butyl Methoxydibenzoylmethane, Ethylhexyl Triazone, Bis-Ethylhexyloxyphenol Methoxyphenyl Triazine, C12-15 Alkyl Benzoate, Diethylamino Hydroxybenzoyl Hexyl Benzoate, Glycerin, Phenylbenzimidazole Sulfonic Acid, [unclear], Octocrylene, Acrylates/C10-30 Alkyl Acrylate Crosspolymer, Oleth-20, Tocopherol, Aminomethyl Propanol, Carbomer, Disodium EDTA, Sodium Chloride, Parfum, Citric Acid, Sodium Hydroxide, Phenoxyethanol, Ethylhexylglycerin, Alpha-Isomethyl Ionone, Limonene, Linalool, Citronellol.
Hautverträglichkeit: • Parfümfrei • Mit Bio-Kamille • Geeignet für empfindliche Baby- & Kinderhaut ab dem Alter von 6 Monaten
After: the change to make
If chamomile ingredients are not added to the formulation, the “Mit Bio-Kamille” claim and related efficacy implications should be removed; if indeed added, it should be fully labeled in the ingredient list using the standard INCI name.
Rules cited
- REGULATION (EU) No 655/2013 p. 3
- 5
Questions regarding the presentation method of packaging recycling symbols (Der Grüne Punkt / EPR marking)
Directly printing the Der Grüne Punkt symbol on the packaging as identification for recycling and Extended Producer Responsibility (EPR) compliance, rather than presenting it through digital standard methods such as a QR code according to the new system, may not comply with the labeling requirements of the new regulations.
Before: on the label
[Der Grüne Punkt logo] [HDPE recycling symbol 2] HDPE
[Der Grüne Punkt logo]
After: the change to make
Review whether the EPR compliance marking needs to be presented via a QR code or other standardized digital data carrier, and confirm that packaging recycling markings comply with the latest harmonized regulations to avoid misleading consumers regarding recyclability.
Rules cited
- REGULATION (EU) 2025/40 p. 50
- 6
Placeholder / not a real, valid number
The label contains suspected placeholders or non-genuine numbers/dates, which should be corrected to genuine and valid values.
Before: on the label
0 0800 00 00 00
0000 0000.0000.AA.01
After: the change to make
Please correct placeholders to real and verifiable numbers/dates/batch numbers.
Rules cited
- Data authenticity check
Points to verify on your file
Some requirements depend on the formula, the print file or documents that are not on the label. The report lists them as checks to make. A few from this run:
REGULATION (EC) No 1223/2009 p. 15
Check the internal formulation batching ratio table to confirm that ingredients with a concentration greater than 1% are indeed listed in descending order of weight - in compliance with the requirements on page 15 of REGULATION (EC) No 1223/2009.
DIRECTIVE (EU) 2024/825 p. 12
Review the implementation timeline of EU Directive (EU) 2024/825, and include a reminder of the legal guarantee of conformity in product sales information or labeling as required - ensure compliance with EU consumer rights protection regulations.
DIRECTIVE 2005/29/EC p. 14
Confirm and prepare valid authorization or contract proof documents for Der Grüne Punkt (Green Dot) - ensure compliance with the legal authorization requirements for marks on page 14 of DIRECTIVE 2005/29/EC.
DIRECTIVE 2005/29/EC p. 14
Prepare clinical test reports and physician endorsement documents for “Pediatrically confirmed (Kinderärztlich bestätigt)”, and provide supplementary explanations corresponding to an asterisk at an appropriate position on the packaging - ensure compliance with the authenticity requirements for claim endorsements.
REGULATION (EC) No 1223/2009 p. 138
Cross-check the product formulation and raw material specifications to confirm that the concentration of Phenoxyethanol in ready-for-use preparations does not exceed 1.0% - complying with the provisions of Annex V of REGULATION (EC) No 1223/2009.
REGULATION (EC) No 1223/2009 p. 143
Check the product formulation and test reports to confirm that the concentration of Phenylbenzimidazole Sulfonic Acid expressed as acid does not exceed 8% - complies with the provisions of Annex VI of REGULATION (EC) No 1223/2009.
How this report was produced
- Two images of the label were uploaded, the front and the back, as one review. A review takes PNG or JPG images: up to 6 per review and 50 MB in total. PDF files cannot be uploaded yet.
- The market chosen was the European Union, for cosmetics. Each review checks one market.
- The findings are the review's own words, unchanged. Only the rule references were tidied (2005_29_EC is shown as 2005/29/EC) and the photos cropped to the bottle. The boxes on the label were drawn by RegaaS's label annotation, run again on the same findings on November 10, 2026.
- A report is a documented review against the rules RegaaS applies. It is not legal advice and does not guarantee regulatory approval.