The proposal introduces a new Article 20¹ into the Consumer Code, allowing specific mandatory information required under EU cosmetics legislation to be provided electronically via a QR code or an equivalent electronic identifier placed on the product container or packaging.

Under the draft law, only the following mandatory information may be provided electronically:
– particular precautions for use (Article 19(1)(d) of EU Cosmetics Regulation);
– the function of the cosmetic product (Article 19(1)(f) of EU Cosmetics Regulation); and
– the list of ingredients (Article 19(1)(g) of EU Cosmetics Regulation).

This information must be accessible through a readable and easily accessible QR code or equivalent electronic identifier, which directs consumers to a dedicated webpage for the relevant cosmetic product.

Other mandatory information under Article 19(1) of the EU Cosmetics Regulation must be displayed physically on the container or packaging.

Conditions applicable to the QR-code webpage

The draft law also establishes several conditions applicable to the webpage accessed via the QR code.

In particular, the webpage must:
– include the full mandatory information in Romanian, with the option to provide additional languages;
– contain complete and up-to-date information in accordance with Cosmetics Regulation; and
– remain accessible throughout the marketing period of the cosmetic product and for at least 12 months after the last unit of the relevant batch has been placed on the market.

Where the QR code is temporarily inaccessible, the required information must still be made available either via the responsible person’s general website or through customer service channels.

The responsible person remains fully liable for compliance with the EU Cosmetics Regulation.

Current status

The draft law is currently before the Romanian Senate, the first chamber in this legislative process. If adopted by the Senate, the proposal will be forwarded to the Chamber of Deputies, which will be the decision-making assembly.

Implications

The proposal reflects a wider European movement toward digital product information systems, mirroring ongoing EU initiatives such as QR‑code labelling and digital-product passports. If adopted, it would offer greater flexibility for responsible persons in the cosmetics sector, while ensuring that consumers have access to safety and product information.

For more information on how this draft law could affect your Romania-based business and legislative developments in the cosmetics sector, contact your usual CMS contact or the authors of this article: Cristina Popescu and Carmen Turcu.