Cosmetics regulations: differences and similarities between Switzerland and the European Union
European and Swiss cosmetics regulations are known for their high standards in terms of safety, traceability, and transparency. Although legally distinct, these two frameworks are very similar in technical terms. Switzerland, which is not a member of the European Union, has chosen to harmonize much of its legislation with Regulation (EC) 1223/2009, while retaining certain national specificities. This article presents the commonalities, key differences, and implications for brands wishing to market their products in Europe and Switzerland.
- A largely harmonized regulatory framework
European Union
European regulations are based on Regulation (EC) No. 1223/2009, which governs the safety, composition, labeling, and marketing of cosmetic products.
Switzerland
Switzerland bases its regulations on the FDHA Ordinance on Cosmetics (OCos) and the requirements of the FSVO. The OCos incorporates most of the principles of the European regulation, in particular the requirement for a DIP, safety assessment, good manufacturing practices, ingredient requirements, and labeling rules.
- DIP / PIF : similar requirements in terms of content, different in terms of the legal framework
In the European Union, the DIP is mandatory and must include the product description, test reports, safety assessment, evidence of claims, labeling compliance, and demonstration of good manufacturing practices.
In Switzerland, the DIP The requirements are virtually identical, but the assessor must have training that is recognized by the Swiss authorities. The Swiss authorities also attach particular importance to the consistency and traceability of the file.
- Notification: a major difference
European Union
Each product must be notified on the CPNP portal before it is placed on the market.
Switzerland
There is no notification platform. No prior registration is required before marketing.
This difference implies distinct strategies depending on the target markets.
- Labeling: similar rules, stricter language requirements in Switzerland
In the European Union, labeling must be written in a language that is understandable to consumers in the country of sale.
In Switzerland, labeling must be available in French and German, with Italian possibly required depending on the region. The responsible person must be based in Switzerland for products sold only on the Swiss market.
The mandatory information, INCI list, warnings, contents, and shelf life remain unchanged.
- Product composition: high degree of harmonization but some possible differences
Switzerland resumes in OCos the annexes to the European regulation on prohibited and restricted substances, preservatives, UV filters, and colorants. However, Switzerland reserves the right to adapt certain lists according to its own assessments, which sometimes creates specific differences between the two systems.
- Claims: strict requirements in both systems
The European Union and Switzerland apply the same principles to regulate claims: sincerity, verifiability, proof, fairness, and regulatory compliance. Swiss authorities are known to be very strict on the concept of truthfulness, particularly for natural products and skincare products with dermatological claims.
- Required tests: same scientific requirements
Both frameworks refer to the same international standards, including OECD guidelines and validated alternative methods. The requirements for safety, stability, tolerance, and efficacy are equivalent.
Conclusion
Swiss and European cosmetics regulations are highly harmonized, but certain differences must be taken into account: no notification requirement in Switzerland, specific language requirements, recognition of the evaluator, slight variations in the ingredient appendices, and specific labeling requirements. Brands wishing to sell in Switzerland and the European Union must understand these nuances in order to ensure a smooth and secure market launch.
Services offered by Lelégard Laboratories
Lelégard Laboratories supports brands targeting the Swiss and European markets. We offer cosmetic formulation, contract manufacturing, and the production of DIP EU and Swiss compliance, safety assessment by a toxicologist recognized in Switzerland, verification of multilingual labeling, testing, and comprehensive regulatory support.
Our expertise covers compliance for the French, European, and Swiss markets.