Cosmetic Labelling in Germany: What Must Be on the Pack, and in Which Language

The mandatory particulars under Article 19

Article 19(1) requires the following information on the container and on the packaging, in indelible, easily legible and visible lettering. Where a product has an outer box and an inner container, both carry the particulars, with the exceptions noted below.

Where it is impossible for practical reasons to put the precautions (d) or the ingredients (g) on the label, they may appear on an enclosed leaflet, label, tape, tag or card, and the pack must carry the hand-in-book symbol from Annex VII to point to it. For soap, bath balls and other small products where even that is impossible, the ingredients may be on a notice next to the product at the point of sale. German retailers accept the leaflet route for small sizes. They do not accept it as a way to avoid redesigning a pack that has room.

The German language rule

Article 19(5) of the regulation leaves the language of the content, the durability, the precautions, the function and the "may contain" wording to the member state where the product is made available. Germany has used that option. Section 4 of the German Kosmetik-Verordnung requires those particulars in German. The practical consequences:

• "Best used before the end of" becomes "Mindestens haltbar bis Ende" or the hourglass symbol with the date.
• The function must be German or unmistakable from the pack. "Serum" works. "Overnight recovery complex" does not.
• Precautions must be German: "Kontakt mit den Augen vermeiden" rather than "Avoid contact with eyes".
• The nominal content with "ml" or "g" is already language-neutral; "e" stays "e".
• The INCI list is not translated. "Aqua", "Parfum" and "CI 77891" are correct in every EU language. The phrase before the list may be "Ingredients" in any EU language; "Inhaltsstoffe" is common in Germany but not required.
• The "may contain" wording for shade ranges, "+/-" or "kann enthalten", must be German if written out. The symbol "+/-" is accepted.

Multilingual packs are allowed and common in DACH. A pack with German, English and French side by side is accepted by every German retailer as long as the German text is complete and legible. A pack with English only and a German sticker is accepted by drugstores and online retailers and, in our experience, resisted by prestige perfumeries and department stores, where the look of the pack is part of the listing decision. The sticker also has a regulatory consequence covered below.

The ingredient list in detail

The ingredient list is the part of the label that German authorities check most systematically, because it can be checked against the Product Information File and the CPNP notification without opening the product. The rules under Article 19(1)(g) and the Commission's common ingredients glossary, currently Decision (EU) 2022/677:

• Ingredients in descending order of weight at the time they were added. Ingredients at concentrations below 1 percent may be listed in any order after those above 1 percent.
• Colourants other than hair colourants may be listed in any order after the other ingredients, using CI numbers. For decorative cosmetics sold in a range of shades, all colourants used in the range may be listed, preceded by "may contain" or "+/-".
• Perfume and aromatic compositions are listed as "Parfum" or "Aroma". Their raw materials are not listed, with one large exception: the fragrance allergens.
• Fragrance allergens listed in Annex III must be named individually when they exceed 0.001 percent in leave-on products and 0.01 percent in rinse-off products. Regulation (EU) 2023/1545 added 56 substances to that list, which now covers more than 80 entries. Products placed on the market from 31 July 2026 must use the new list; products already on the market have until 31 July 2028. If your label still shows the old 26 allergens, it is out of date for any product launched in Germany this year.
• Nanomaterials carry the word "nano" in brackets after the ingredient name, for example "Titanium Dioxide [nano]".
• INCI names follow the glossary. Trade names, plant names in English or local-language descriptions in place of INCI names are a common finding on packs from outside the EU.

Claims on the label and in the listing

Everything the pack says beyond the mandatory particulars is a claim, and claims have two sets of rules in Germany.

The first is European. Regulation (EU) No 655/2013 sets the common criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. The Commission's technical document on claims explains what that means for the wording brands like most. "Free from" a legally permitted ingredient is not allowed when it denigrates that ingredient, so "free from parabens" fails and "free from alcohol" for a product aimed at people who avoid alcohol for religious reasons passes. "Hypoallergenic" requires evidence of a minimised allergenic potential. "Not tested on animals" is misleading in the EU, because animal testing is prohibited for everybody. Efficacy claims with numbers need the study in the Product Information File. The guide on CPSR, PIF and CPNP covers what the file must contain.

The second is German, and it is new. On 27 September 2026 Germany transposed the EU Directive on empowering consumers for the green transition into the Act against Unfair Competition, the UWG. Since that date, generic environmental claims such as "umweltfreundlich", "klimaneutral", "nachhaltig" or "grün" are prohibited unless the brand can show recognised excellent environmental performance for the specific claim. Sustainability labels may only be used when they are based on a certification scheme or established by a public authority. Claims based on offsetting, "climate neutral through compensation", are prohibited outright. Products placed on the market before 27 September 2026 may be sold off until 27 September 2028. For a brand printing packs for Germany now, the safe rule is simple: no environmental adjective without a certificate behind it, and no certificate logo you cannot name the scheme for.

Germany enforces competition law differently from most countries. Competitors and consumer associations can send a formal warning letter, an Abmahnung, with a cease-and-desist declaration and a fee, without going through a court first. Claims on cosmetic packs are a regular target. A German lawyer's review of the front panel before the first print run costs less than the first Abmahnung.

Stickers, overlabels and who notifies

Many brands enter Germany with their existing pack and a German sticker that carries the translated function, precautions and durability wording. This is legal, subject to three conditions. The sticker must be indelible and legible for the life of the product. It must not cover other mandatory particulars. And whoever applies the translation has a regulatory duty: under Article 13(3) of the regulation, a distributor that translates any element of the labelling on its own initiative must submit its own CPNP notification for that product in Germany, with the original and translated product name and its own details. If your Responsible Person or your own EU entity applies the sticker, it is covered by the main notification. If your German importer does it, the importer notifies.

The commercial side is less generous than the legal side. Drugstores and online retailers accept a stickered pack. Douglas, department stores and niche perfumeries generally do not, and a prestige brand that arrives with a sticker tells the buyer that Germany was an afterthought. If the plan is prestige retail, budget for a German or multilingual print run before the first listing meeting. The guide on German beauty retailers explains what each channel expects.

What is not required in Germany, and often added by mistake

• The Triman logo. A French obligation under French law. It is not required in Germany, and a France-only pack that carries it is fine, but do not add it to a pack designed for Germany in the belief that it is an EU symbol.
• The Grüner Punkt. A licensed trademark of one German packaging scheme, not a legal requirement. Using it without a licence is a trademark problem. What Germany does require is registration of your packaging in the LUCID register and a contract with a dual system, which is not a label matter at all. The guide on selling cosmetics in Germany explains LUCID.
• A recycling symbol or resin code. Optional today. The EU Packaging and Packaging Waste Regulation, in force since 12 August 2026, introduces harmonised sorting labels on packaging from 12 August 2028. Artwork printed in 2027 should leave room for them.
• The CPNP reference number. Not a label element. Retailers may ask for it in listing forms, but it does not go on the pack.
• A German importer address in addition to the Responsible Person. Not required by cosmetics law. Some retailers ask for a German contact on the pack for customer service reasons, which is a commercial request, not a legal one.

One German rule that is not a label element but catches brands online: the Preisangabenverordnung requires the unit price per 100 ml, 100 g or 1 litre next to the selling price in every German shop and online listing. Retailers handle this, but a brand that runs its own German web shop must show it.

Austria and Switzerland

Austria applies the same EU regulation and requires German for the same particulars, so a pack that is right for Germany is right for Austria. Switzerland is outside the EU but has aligned its Ordinance on Cosmetics with the EU rules. The Swiss label must carry the name and address of a responsible person in Switzerland, and the particulars must appear in at least one of the official languages; for German-speaking Switzerland, where most of the retail is, that means the German pack works, with the Swiss address added. There is no CPNP equivalent in Switzerland, and the Product Information File must be available to the cantonal authorities on request.

The pre-print checklist

• EU Responsible Person name and EU address on container and packaging, plus country of origin for imported products.
• Nominal content in g or ml, in German-compatible form.
• Either the best-before date (30 months or less) or the PAO symbol with months (more than 30 months), decided by the stability data in the CPSR.
• Precautions for use in German, including every warning triggered by Annexes III to VI for your ingredients.
• Batch number on the container, at minimum on the packaging if the container is too small.
• Function in German, unless obvious from the pack.
• "Ingredients" list in INCI names, descending order, colourants with CI numbers, "Parfum" plus allergens above threshold under the 2026 list, "[nano]" where relevant.
• "May contain" or "+/-" for shade ranges, in German if written out.
• Hand-in-book symbol if precautions or ingredients are on a leaflet.
• No "free from" claim that denigrates a permitted ingredient; no "not tested on animals"; no environmental adjective without a named certification behind it.
• Efficacy claims with numbers backed by a study in the PIF.
• No Triman, no Grüner Punkt without licence, no French-only or English-only mandatory particulars.
• If a sticker carries the German text: who applies it, and whether that party has filed its own CPNP notification.

Questions brands ask us

Tity Sonko

Founder and Managing Director of SONKO Consulting GmbH in Leverkusen, Germany. Tity works with international prestige beauty brands on their entry into Germany, Austria and Switzerland, from the first compliance check to the first retail order. She writes the weekly newsletter The DACH Prestige Signal.