E-commerce of beauty products: What are the obligations?

  • February 14, 2023

Since the start of the pandemic online sales have grown even faster, with many brands increasing their focus on digital channels, however, as with physical sales, there are rules to comply with.

On the Internet, sellers of beauty products must comply with many distance selling provisions and include them on their online sales site:

- The essential features of the product
- The price
- The terms of payment, delivery or performance
- The costs and the delivery period in which the professional undertakes to deliver the product (in the absence of precision, this period is set at 30 days after the act of purchase, at the end of which the consumer can cancel his order if it has not been delivered)
- The existence or absence of a right of withdrawal (set at 14 days for Internet sales)
- the duration and validity of the offer
- the identity of the seller, his postal, telephone and electronic contact details, and the nature of his activities
- The costs of using the remote communication technique, codes of good conduct, guarantees and warranties, cancellation procedures, dispute resolution methods.


Manufacturers must also comply with the provisions of Article 19 (Labeling) of the Cosmetics Regulation 1223/2009 and include on their website:

- The name or company name and address of the person responsible
- The nominal content at the time of packaging, indicated in weight or volume
- The date until which the cosmetic product, stored under appropriate conditions, continues to fulfil its initial function
- Special precautions for use
- The function of the cosmetic product, unless it is clear from its presentation
- The list of ingredients.


It is important not to forget that the claims made on the website must comply with Article 20 of the Cosmetics Regulation (product claims), and Regulation 655/2013 on Common Criteria).


What then about certain information that appears on the packaging, such as the PAO or the batch number, which is not usually seen on the Internet? 

The PAO is substantial information that is important at the time of purchase and can guide the consumer's choice, and it is recommended to make it available online. 

The lot number, on the other hand, is related to traceability between supplier and distributor. It is not useful in the context of a generic presentation of a care product and therefore does not necessarily have to appear on the Internet. 

Another point to be clarified is the withdrawal period. If consumers are entitled to 14 days, brands can invoke hygiene measures and not accept the return of an unsealed product. If these reasons are quite legitimate, it is up to sellers to inform their customers in advance.

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