Stating the Function on an EU Label When It Is Not Obvious

Pick up a bottle of shampoo and nobody needs a label to tell them what it does. Pick up a small unlabeled jar of pale cream with no other context, and the function is genuinely unclear. That gap is exactly what the EU's function statement requirement exists to close.

The rule in plain terms

Regulation (EC) No 1223/2009, the framework governing cosmetics across the EU, requires that a product's function appear on the label unless that function is clear from its presentation. The logic is straightforward: a consumer should be able to understand what they're buying and how to use it safely, and most of the time the packaging, shape, and context already communicate that without extra text. A tube of toothpaste-shaped product sitting next to a toothbrush icon doesn't need "for cleaning teeth" spelled out. A bar of soap shaped like, well, a bar of soap, generally doesn't either.

When it gets less obvious

The requirement matters most for products where the format doesn't tell the whole story:

• Serums and ampoules in plain glass droppers or vials. A clear liquid in a small bottle could be a facial oil, an eye serum, a hair treatment, or something else entirely. Without a stated function, a consumer has no reliable way to know what it's for or how to use it.
• Multi-use balms sold in tins or jars that could plausibly be a lip balm, a cuticle balm, a solid perfume, or a general skin salve. The format alone doesn't disambiguate.
• Novelty or artisanal soap shapes that don't read as soap at all until you've used them. A soap bar shaped and colored like a slice of cake or a piece of fruit is the classic example. If it doesn't look like soap, it needs to say what it is.
• Powder or solid products in plain containers, where a fine white powder could be a dry shampoo, a setting powder, or a bath additive.

Two worked examples

Soap example. A traditional rectangular bar in a wrapper that says "handmade soap" with an image of lather doesn't need much more. A whimsical bar shaped like a cupcake, sold in a market stall with minimal packaging, absolutely needs a stated function like "soap bar for cleansing" somewhere on the label, because a customer could reasonably mistake it for something else entirely, including, worst case, something edible.

Serum example. A dropper bottle labeled only with a brand name and an ingredient highlight like "Vitamin C" doesn't tell a consumer what to do with it. Stating the function clearly, "facial serum" or "brightening serum for face," removes any ambiguity about where and how it's meant to be used.

What the function statement should actually say

It doesn't need to be a marketing paragraph. A short, clear phrase describing what the product does and generally where it's used is enough: "moisturizing face cream," "exfoliating body scrub," "conditioning hair mask." The goal is comprehension, not persuasion. This sits alongside other EU labeling requirements, like the ingredient list in INCI order and the standard EU symbols, but it's a distinct requirement worth checking specifically rather than assuming your ingredient list or brand name covers it.

Where this fits with your broader EU filing

The function statement is a labeling detail, but it lives inside the larger EU compliance picture: notifying the product through the CPNP portal, appointing a Responsible Person established in the EU, maintaining a Product Information File, and having a Cosmetic Product Safety Report signed by a qualified safety assessor. Function statements, ingredient declarations, and safety assessments all need to agree with each other, since a mismatch between what your label claims and what your CPSR supports is the kind of inconsistency that draws attention.

Cosmetic Comply's EU support is on its roadmap alongside the US and Australia, building on the same core approach already live for Canada: matching ingredients precisely and having a real reviewer check the work before anything gets filed. Until then, a quick self-check on whether your product's function would be obvious to a stranger holding it for the first time is a fast, free way to catch a labeling gap before it becomes a bigger conversation with your Responsible Person.