How to make a useful product-label record
A label record preserves what a particular product’s packaging says at a particular time. It should distinguish the photographed text from your interpretation. This guide creates an observation record, not a certificate that the label or product meets legal requirements.
KEY TAKEAWAYS
- Keep the packaging text separate from commentary.
- Identify variant and record date.
- Explicitly mark fields as unreadable or not observed.
Record the package identity and photographed faces
Use a proposed photo inventory covering the container’s front, back and base, all sides of the outer box, and any attached leaflet, tag or card. Link each image to the same item identity and observation date. Record product name, shade or variant, item code and visible batch identifier; label any unavailable panel as not photographed instead of leaving an unexplained gap.
For an EU-cosmetic observation record, Article 19 provides the field categories: responsible person’s name/address; imported product’s country of origin; nominal content; minimum durability or period after opening where applicable; precautions; batch/reference; product function; ingredient list. Record the wording and the panel where each is seen. The article includes exceptions and ways to place some information elsewhere, including an attached leaflet; not every field belongs on every panel. This inventory alone is not a compliance verdict. [1]
Transcribe the packaging as it is
For each photo, record its panel and filename, then copy names, numbers, punctuation, warnings and “may contain” text as printed. Use separate fields for your transcription and comments. Mark blurred text unreadable and a field not found as not observed; neither should be silently turned into an absent ingredient or a legal defect.
Add interpretation in a separate record
If you check an ingredient name in CosIng, attach the entry and access date to a separate search record, leaving the label text unchanged. The Commission describes CosIng as informative rather than an approval. Close with a summary of item identity, observation date, photo links and fields marked unreadable or not observed. Keep it attached to the face inventory, exact transcriptions, separate comments and information-category observations above; the summary does not replace those records. Ingredient comparison and legal assessment are separate tasks. [2]
Article Sources
- European Union / EUR-Lex — Regulation (EC) No 1223/2009 on cosmetic products — consolidated text, 1 September 2025
Regulatory source
Printed pages 19–21, Article 19(1)(a)–(g) and (2): responsible person/address, imported origin, nominal content, durability/PAO, precautions, batch/reference, function and ingredients; stated exceptions and attached-information options. Used to structure an observation record, not certify a particular label’s compliance.
Consolidated text as of:
- European Commission — Cosmetic ingredient database
Primary source
Overview and search-description passages: common ingredient names, CAS/ELINCS/EINECS identifiers, records since 1976 and active versus historical entries. Important notice: the database is informative and non-binding; inclusion is not ingredient-use approval. Overview reviewed, without testing the search engine or individual records.
Written and reviewed with AI assistance using the linked sources. No hands-on product testing or independent specialist review was performed.
Commercial resource from our ecosystem
Professional nail materials and tools with NailMarket.eu — a shop in our ecosystem.
NailWiki, BELOM, NailMarket, BELOM App and NaNails are projects of BELOM Group OÜ, as identified by the owner. Molokom catalogue images are supplied through our NaNails shop; this commercial relationship is not independent product-test evidence.
