Cosmetics law: Differences and similarities between Switzerland and the European Union
The cosmetic legislation of the European Union and Switzerland is known for its high standards of safety, traceability, and transparency. Although both systems are legally independent, there are numerous technical similarities. Switzerland, which is not a member of the European Union, has aligned a large part of its regulations with EU Regulation (EC) 1223/2009, while retaining specific national requirements. This article highlights the most important similarities, differences, and implications for brands that want to market their products in both the EU and Switzerland.
A largely harmonized legal framework
European Union
The legislation is based on EU Cosmetics Regulation (EC) 1223/2009, which regulates the safety, composition, labeling, and marketing of cosmetic products.
Switzerland
Swiss requirements are based on the EDI Ordinance on Cosmetic Products (VKos / OCos) and the requirements of the BLV. The OCos adopts most of the EU rules, including the obligation to provide a product information dossier, safety assessment, good manufacturing practices, provisions on ingredients, and labeling.
DIP/PIF: virtually identical in content, legally different
In the EU, the product information file is required by law and includes the product description, test reports, safety assessment, evidence of advertising claims, label review, and presentation of good manufacturing practices.
In Switzerland, the contents of the dossier are almost identical. However, safety assessors must have a qualification recognized by the Swiss authorities. In addition, the authorities attach particular importance to the traceability and consistency of the dossier.
Product notification: a key difference
European Union
Every cosmetic product must be registered on the CPNP portal before being placed on the market.
Switzerland
There is no registration portal in Switzerland. Registration prior to market entry is not required.
This leads to different strategies depending on the target market.
Labeling: similar rules, stricter language requirements in Switzerland
In the EU, labeling must be in a language that is understandable in the respective member state.
In Switzerland, labeling must be in French and German. Italian may be required depending on the sales region. For products sold exclusively in Switzerland, the responsible person must be based in Switzerland.
The mandatory information, INCI list, warnings, and quantity and shelf life information are largely identical.
Ingredients: extensive harmonization, occasional deviations possible
Switzerland adopts the EU lists of prohibited, restricted, and permitted substances in OCos. However, it reserves the right to adjust certain assessments independently. This may occasionally lead to differences between the two systems.
Advertising claims: strict requirements in both sets of regulations
Both the EU and Switzerland require that cosmetic advertising claims be true, verifiable, comprehensible, and not misleading. The Swiss authorities are considered particularly strict, especially when it comes to natural products and dermatological claims.
Required tests: same scientific standards
Both systems refer to international standards such as OECD guidelines and validated alternative methods. The requirements regarding safety, stability, skin compatibility, and efficacy are equivalent.
Conclusion
The cosmetic regulations in Switzerland and the European Union are highly harmonized. Nevertheless, there are some important differences: no product notification in Switzerland, specific language requirements, recognition of safety assessors, possible deviations in substance lists, and special labeling requirements. Brands that want to operate in both markets must carefully consider these differences to ensure smooth and secure market access.
Services provided by Laboratoires Lelégard
Laboratoires Lelégard supports brands targeting the Swiss and European markets. We offer formulation development, contract manufacturing, and the creation of compliant DIP/PIF for the EU and Switzerland, safety assessments by toxicologists recognized in Switzerland, review of multilingual labeling, performance of the necessary tests, and comprehensive regulatory support.
Our expertise covers full compliance for the French, European, and Swiss markets.
