EU Sunscreen Labeling Checklist: UVA Mark, Warnings, and Claims to Avoid

When sourcing and labeling sunscreens for the EU market, clarity and compliance are non‑negotiable. Buyers and brand managers must ensure every claim, symbol, and warning line meets current Cosmetics Regulation and COLIPA (now Cosmetics Europe) UVA labeling guidance. Below is a practical checklist to help your procurement or labeling project move faster without risking re‑labeling or market withdrawal.

Essential EU Sunscreen Labeling Elements

• SPF statement: Must be verified by ISO 24444 in vitro testing. No rounding up — report tested SPF.
• UVA circle logo: Permitted only if UVA protection factor ≥ ⅓ of the tested SPF value.
• Mandatory warnings: “Do not stay too long in the sun,” “Keep babies and young children out of direct sunlight,” and “Overexposure is a serious health threat.”
• Responsible person and address: Required on all EU cosmetics labels.
• Batch number and nominal content: Must appear unless impracticable for small packs.

Claims That Trigger Regulatory Review

Avoid Over‑Promising Phrases

• “Sunblock” or “Total protection” — not accepted under EU cosmetics guidance.
• “Waterproof” — use “water‑resistant” only if validated by ISO 16217/ISO 18861.
• “All‑day protection” — long‑wear claims must match stability and re‑application instructions.
• “Clinically proven SPF” — only if supported by independent lab tests with full report.

Substantiation Required for Positive Claims

• Broad‑spectrum — UVA/UVB verified through ISO 24443.
• Anti‑pollution, antioxidant or other topical benefits — include in Product Information File (PIF) claim substantiation folder.
• Dermatologically tested — factory must supply full protocol and irritation summary.

Packaging & Symbol Requirements

Buyer Action Steps

• Confirm the contract lab uses ISO‑validated SPF/UVA test methods.
• Request a complete PIF audit checklist before artwork approval.
• Pre‑approve all label text with your regulatory partner before mass printing.
• Keep copies of CoA, SDS, stability and microbiology results for batch release.

FAQ

Do I need the UVA circle symbol on all sunscreens?

Only if the UVA protection is proven to be at least one‑third of the SPF value; otherwise, omit the symbol.

Can I translate mandatory warnings?

Yes, but the official meaning must remain identical. Always validate local language versions with your EU Responsible Person.

Is it legal to claim “Eco‑friendly” or “reef‑safe”?

These environmental claims require data. Request supporting studies for ingredient environmental impact before printing.

What is the consequence of missing a batch code?

Missing or unreadable batch coding breaks traceability and can lead to product recall or market withdrawal.

Do I need to register sunscreen formulations in CPNP?

Yes, all cosmetic sunscreens sold in the EU must be notified through the Cosmetic Products Notification Portal (CPNP).

Request a Quote to get a compliant EU‑ready sunscreen formulation and full labeling support.

Hi, I'm Alex Zong, hope you like this blog post.

With more than 20 years of experience in OEM/ODM/Private Label Cosmetics, I'd love to share valuable knowledge related to cosmetics & skincare products from a top-tier Chinese supplier's perspective.