NO LABEL & PRIVATE LABEL SERVICE

For products sold as NO LABEL:

NO LABEL products are sold via e-commerce, directly through the company's website, following standard online purchase procedures.

The Customer must ensure correct labeling, comply with current regulations, and follow all commercialization procedures for the product.

GelPolish.it will exclusively provide the INCI % for labeling and for notification to the European CPNP portal.

GelPolish.it

regarding the commercial relationship with our Customers, is pleased to inform you about Regulation (EC) 1223/2009 on cosmetic products.

On December 22, 2009, the new Cosmetics Regulation, approved by the European Parliament and the Council, was published in the Official Journal of the European Union, with the aim of harmonizing existing provisions on the matter.

The regulation defines roles, including the most important points:

manufacturer: a natural or legal person who manufactures a cosmetic product or has it designed or manufactured and markets it under their name or trademark. (In this case: Customer).

The Customer is the Responsible Person.

Art. 4 paragraph 3. For cosmetic products manufactured within the Community and not subsequently exported and re-imported into the Community, the manufacturer established within the Community shall be the responsible person. (In this case: Customer).

Article 5 Obligations of responsible persons 1. Responsible persons shall ensure compliance with Articles 3, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, Article 19, paragraphs 1, 2 and 5, and Articles 20, 21, 23 and 24. (In this case: Customer)

Their name or business name and address must be included on the labeling (Art. 19.1 lit. a).

Article 13 Notification 1. Before placing the cosmetic product on the market, the responsible person shall submit the following information to the Commission in electronic format. (In this case: Customer)

Please review EC Regulation 1223/2009.

For information, clarifications, and advice on the matter, we can put you in contact with a consulting office and a professional who can assist you. We would like to clarify that the professional operates autonomously and independently of JOX Cosmetics srl, and their consultation will be at the Customer's expense. By purchasing, the customer confirms ACKNOWLEDGMENT AND AWARENESS of REGULATION (EC) 1223/2009.

 

For PRIVATE LABEL - CUSTOMIZED products

Products marketed as Private Label are reserved for registered customers and are not sold directly through the e-commerce website. The supply of Private Label products is exclusively subject to registration, definition of commercial data, and submission of orders through dedicated documentation (e.g., Excel order file or equivalent documentation), according to the terms agreed upon by the parties.

Information on the website regarding Private Label products is solely descriptive and informative and does not constitute a direct offer for sale, nor does it create any contractual obligation in the absence of a formal order confirmation.

The submission of a Private Label order, together with its acceptance by the company, constitutes the sole prerequisite for the conclusion of the supply contract.

By accepting these terms of sale, the Customer acknowledges and accepts the distinction between the two supply methods and their respective operating procedures, recognizing that Private Label sales follow a dedicated process, distinct from e-commerce, and governed by specific agreements.

In relation to the established commercial relationship, the company informs the Customer that the supply of products and their labeling are governed by Regulation (EC) No 1223/2009 on cosmetic products and other applicable national and community provisions.

The labeling of the supplied products is prepared by the company exclusively in compliance with current cosmetic regulations, showing only the mandatory indications provided by Regulation (EC) No 1223/2009, according to criteria of conformity, essentiality, and regulatory correctness.

The company does not evaluate, propose, or include on labels any claims, wording, or statements of a commercial, promotional, or marketing nature, including indications of origin or other voluntary wording not mandatory by law.

Any requests for customization of the labeling, including modifications or additions to the standard proposal, are not part of the ordinary supply and must be subject to specific and separate agreements, formalized in writing. In the absence of such agreements, the provided labeling is considered compliant and definitive.

Pursuant to Regulation (EC) No 1223/2009, the Customer, as the entity marketing the product under their own name or brand, holds the role of Manufacturer and, for cosmetic products manufactured within the European Community and not exported and re-imported, assumes the role of Responsible Person, in accordance with Article 4, paragraph 3, of the same Regulation.

In this capacity, the Responsible Person is obliged to ensure compliance with Articles 3, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, Article 19, paragraphs 1, 2 and 5, and Articles 20, 21, 23 and 24 of Regulation (EC) No 1223/2009, including obligations related to correct labeling, notification to the European CPNP portal, and placing the product on the market.

The name or business name and address of the Responsible Person must be indicated on the label, in accordance with Article 19, paragraph 1, letter a), of Regulation (EC) No 1223/2009.

The company exclusively provides support related to product composition, making available to the Customer the ingredient list with the respective percentage ranges (INCI %), necessary for labeling and notification to the European CPNP portal.

It is understood that the final evaluation, verification, and approval of the labeling are in any case the responsibility of the Responsible Person, who may use their trusted regulatory consultant or proceed independently. The company formulates a labeling proposal compliant with current regulations, but assumes no responsibility for the final validation, use, or placing of the product on the market.

The Customer is required to verify the labeling before printing and, where applicable, before shipping the products. Any observations or requests for modification must be communicated in writing at this stage.

In any case, after 7 (seven) days from the receipt of the labeled products, it will not be possible to raise exceptions, reservations, or disputes regarding the labeling, which will be considered definitively accepted.

For regulatory information, clarifications, or advice, the company can put the Customer in contact with external professionals who operate autonomously and independently of JOX Cosmetics srl; such consulting services are to be understood as being solely at the Customer's expense.

By purchasing the products and accepting these terms of sale, the Customer declares to have read and to be fully aware of Regulation (EC) No 1223/2009, as well as the obligations and responsibilities arising therefrom.

 

Product Information File (PIF)

According to Regulation (EC) No 1223/2009, the Product Information File (PIF) is a dossier that accompanies the cosmetic product as it is placed on the market and is indissolubly linked to:

  • product label,

  • brand under which the product is marketed,

  • company that places it on the market,

  • Responsible Person indicated on the label.

For this reason, the PIF must be prepared and held by the customer at their company and cannot be issued, registered, or held by the supplier.

There is no standard PIF valid for multiple customers: each PIF is specific to the individual product and to the individual entity marketing it.

Our company's role

Our company does not provide ready-made PIFs or generic PIFs, as the dossier must be drawn up based on the label and the data of the customer placing the product on the market.

Upon request, we can put the customer in contact with an external regulatory consultant, who operates independently, for the preparation of the PIF compliant with the Cosmetic Regulation.
The professional relationship occurs directly between the customer and the consultant.