Cosmetics regulations: the rules dictating how to create and translate texts and labels for this innovative sector

What’s the first thing that springs to mind when you hear “cosmetic products”? Is it beauty and personal care? Probably, but this competitive sector is not merely about makeup and cleansing products: there is so much more behind their manufacture. Texts and labels are a significant part of both the production and the commercialization of products, and they must comply with the strict regulations on cosmetics— and the process of translating them must, too.

In 2018, the global cosmetics market grew by an estimated 5.5 percent compared to the previous year. Skincare was the leading category (others included hair care, makeup, perfumes, toiletries, deodorants, and oral cosmetics), accounting for about 39 percent of the global market. Amid the COVID-19 crisis, the global market for Cosmetic Skin Care estimated at US$145.3 Billion in the year 2020, is projected to reach a revised size of US$185.5 Billion by 2027, increasing at a CAGR of 3.6% over the analysis period 2020-2027.

The European cosmetics and personal care market alone was valued at EUR 78.6 billion in 2018, with the largest national markets being Germany (€13.8 billion), France (€11.4 billion), the UK (€10.9 billion), Italy (€10.1 billion) and Spain (€7 billion). With its direct, in-direct and induced economic activity, the industry supports more than 2 million jobs, with 167,730 people directly employed—and a further 1.63 million indirectly employed—in the cosmetics value chain. Europe’s Cosmetics and Personal Care Products Market is projected to grow at a CAGR of 2.6% during the forecast period of (2020-2025). 31.3% is the percentage of consumers who report having bought at least one cosmetic product online during the year 2020, making the beauty sector the 4^th largest e-commerce market in terms of number of customers. But if on one hand online sales have increased, on the other hand in-store sales have unfortunately seen a drop as a result of the pandemic.

According to Cosmeticseurope.eu, the European trade association for the cosmetics and personal care industry, the vast majority of Europe’s 500 million consumers use cosmetics and personal care products every day to protect their health, enhance their well-being and boost their self-esteem. Cosmetics therefore play a critical role in our lives and personal well-being. With such a prospering situation, and forecasted growth, it is certainly no surprise that the cosmetics market relies on translation services to support international demand and grow globally. But what do translation processes need to consider when it comes to preparing cosmetic products for the market?

Regulations on cosmetics exist to ensure that products are safe to be used and this process has not changed despite COVID-19 (what is now speeding up is the pressure on brands to bring innovative products to market) so it is no surprise that they also apply to the translation of labels and marketing assets. The commercialization, manufacturing, and post-manufacturing processes require both straight translation and transcreation, or copywriting, to advertise products. It is essential that this work be carried out by linguists who are not only experts in marketing, but also in chemistry, and who are familiar with the regulations, which impact the language used.

In accordance with cosmetics regulations, every label must include a list of the ingredients in the product, and a product description. New ingredients are continuously being introduced in the cosmetics market. For that reason, the European Commission introduced the regulation known as (EU) 2019/701 and, in April 2019, established a glossary of common ingredient names, which must be used in the labeling of cosmetic products. The new glossary has been in force since May 8, 2020 and is now the mandatory reference for the correct labelling of ingredient lists on cosmetic products. It lists internationally recognized nomenclatures, including the International Nomenclature of Cosmetic Ingredients (INCI), as references. Colorants, other than those used in hair colorants, must be named in accordance with the CI (Color Index) nomenclature, where applicable. Therefore, the CI number should be listed as the common ingredient name. Some ingredients, such as some components used in perfumes, do not have an NCI name. For those ingredients, the ‘perfuming names’, which have been used in the European Union for labeling purposes, should be used. Therefore, for these ingredients, the glossary should list the perfuming names that have previously been used for them in the EU.

Here is an example of how this crucial information is displayed on the label.

Commercializing and advertising products call for both the skills typical of an expert in chemistry and cosmetic products compliance, and also those of a marketer. The linguists involved in this process should be able to make potential customers feel a need for the product and write in compliance with applicable regulations. For example, there is a growing focus on organic products, natural ingredients, and sustainability. Some such claims can only be made if products are recognized by official certifications or seals of quality, and these features cannot be used as marketing tools if the product does not actually possess them. Translators have the difficult task of finding the right balance between promoting a product and providing appropriate information and following cosmetics regulations.

Among product manufacturers that are unaware of the advantages of working with a reliable LSP (Language Service Provider), we have observed three main approaches to the translation of labels and marketing collateral:

Company employees are responsible for translating texts, and there is no internal translation/localization department. Generally speaking, company employees are experts in the product but are not professional translators. Translation is usually an extra responsibility, assigned to employees to save time and/or money. Nevertheless, it is clear that, in the long run, these employees only end up spending the time they would usually devote to their own job on translation. As they cannot work at the speed of a professional translator—and do not have their expertise—neither time nor money is actually saved, and this approach may even result in negative outcomes and branding issues.
Cosmetics companies rely on their distributors for their translation needs. The assumption is that, as distributors are based in the relevant market and speak its language, they will be perfect translators. What happens is often that the quality of translations falls short of expectations. Again, native speakers are not necessarily translators—and companies can allocate a lot of internal resources to this process without achieving the desired standard of translation.
Cosmetics companies use different resources every time, such as employees, language teachers who work for their companies, and even acquaintances, depending on their requirements at any given time. These people are not necessarily experts in either the relevant language or the product. Moreover, if the person responsible for translation is different every time, this inevitably leads to issues with consistency, on top of quality, style, and terminology.

If you are using one of these three approaches, the chances are that your brand reputation is at risk. None of them is a clear translation or localization strategy that ensures quality, consistency, and that the message of the source text is accurately conveyed in the target. Instead, it is highly likely that a lot of internal—and some external—resources will be allocated to something that does not produce results. If you want to make sure your products are translated following the rules, and in a way that inspires your prospects, have a chat with us. Now we can even refresh or build your business animation videos with 3D technology, augmented and virtual reality or get your online show ready with the new virtual booths.