Cosmetic Labeling Requirements in the UK and EU: A Complete Guide

Spectra Cosmetic Compliance

Labelling connects to the CPSR (which specifies warnings) the Responsible Person (whose details appear) and claims. This is our labelling hub.

Where the requirements come from

Cosmetic labelling is governed by the cosmetics regulation Article 19 in the EU with the equivalent provision in the retained UK regulation. It sets out the information that must appear on the container and outer packaging in the language of the country of sale so that consumers and authorities have the essential facts about the product. The UK and EU requirements share the same framework with the main difference being the market specific Responsible Person. These labelling rules apply broadly across personal care products, not just a narrow subset of cosmetics, and anyone selling in Great Britain should be familiar with the relevant uk cosmetics regulation alongside the EU provision.

The purpose is consumer information and safety telling people what the product is what is in it how to use it safely who is responsible for it and how long it lasts. Each mandatory element serves one of those purposes. We work through them below.

1. The Responsible Person's name and address

The label must carry the name and address of the Responsible Person. This identifies the accountable party and gives consumers and authorities a point of contact and it is also the address at which the Product Information File must be held. For Great Britain the Responsible Person must be UK Established for the EU-EU Established. Naming a responsible person on the label is a legal requirement not just good practice.

This element must be accurate and consistent with the notification and the PIF. A mismatch between the address on the label and the Responsible Person on record is exactly the kind of discrepancy an inspection can surface, so consistency across all three matters.

2. Country of origin

For products imported into the UK or EU the label must indicate the country of origin typically shown as ''Made in country'' This applies to cosmetics manufactured outside the market and brought in. It is a straightforward requirement but one that is easy to overlook for imported products.

Brands importing finished products should ensure the country of origin is correctly stated. Our guide to importing cosmetics covers the wider importer obligations, of which this labelling point is one.

3. Nominal content (quantity)

The label must state the nominal content the weight or volume of the product at the time of packaging usually in grams or millilitres. This tells the consumer how much product they are buying. There are limited exceptions for very small packages and certain free samples, but as a rule the quantity must be shown. In practice this means declaring the content in grams (g) for solid products or millilitres (ml) for liquids.

This is a basic but mandatory element. It should reflect the actual filled quantity and be presented clearly. It connects to wider consumer protection and metrology rules on how quantities are declared.

4. Date of minimum durability or period after opening

The label must indicate how long the product lasts in one of two ways. Products lasting up to 30 months must show a date of minimum durability (best before end) date or the hourglass symbol with the date. Products lasting more than 30 months instead show a period after opening (PAO) the open jar symbol with a figure like ''12M'' indicating how many months the product is good for once opened.

This durability information is tied to the product's stability, which the safety assessment considers. Choosing the correct method (durability date vs PAO) depends on the product's shelf life and the figure must be justified by the stability data. It is a small element with a real link to the underlying safety work.

5. Warnings and precautions for use

The label must carry any particular precautions and warnings necessary for safe use. Some warnings are prescribed by the regulation for particular ingredients or product types others are determined by the safety assessment for the specific product. Either way, these are safety critical and must appear as required.

This is a key link between the CPSR and the label: the assessment specifies the warnings a product needs to be safe, and the label must reflect them exactly. A product missing a required warning is non compliant even if everything else is correct. Our CPSR guide explains how warnings are determined.

6. The batch number

Every product must carry a batch number (or manufacturing lot reference) allowing it to be identified and traced. This is essential for traceability if a problem arises with a particular batch it can be identified and if necessary withdrawn or recalled. Where the packaging is too small it may appear only on the outer packaging.

Batch traceability is a quiet but important part of the safety system. It is what makes targeted action possible if a specific production run is implicated in a problem rather than having to act across all of a product.

7. The function of the product

The label must indicate the function of the product unless it is clear from its presentation. This tells the consumer what the product is for example ''shampoo'' ''moisturising cream'' or ''toothpaste'' where that would not otherwise be obvious from the packaging and name.

For many products the function is evident and no separate statement is needed. Where a product's purpose is not clear from its name and presentation a product function statement is required so consumers understand what they are buying and how to use it.

8. The ingredient list (INCI)

The label must carry a list of ingredients, headed 'Ingredients', using INCI names (the standardised International Nomenclature of Cosmetic Ingredients). Ingredients are listed in descending order of weight at the point they are added, down to 1%; ingredients below 1% may be listed in any order after those above 1%. Colourants are listed at the end, often by CI number. These standardised ingredient names, drawn from the international nomenclature for cosmetic ingredients, allow consumers and regulators across different markets to recognise the same cosmetic ingredients regardless of language.

Fragrance is declared as 'parfum' (or 'aroma' for flavour), but any declarable fragrance allergens present above the threshold must be named individually. Nanomaterials are followed by '[nano]'. The ingredient list is one of the most technically exacting parts of a label, and errors in it are common. Getting the INCI names, order and allergen declarations right is essential.

When information can go elsewhere

Where it is impractical to fit all the information on the packaging for example on a very small product some elements may appear on an enclosed or attached leaflet, label, tag or card, with a symbol (an open book / 'refer to leaflet' symbol) on the pack directing the consumer to it. The ingredient list in particular can be handled this way where space genuinely does not allow.

This provides flexibility for small products, but it is not a license to omit information it must still be provided, just in an accompanying format. The mandatory information cannot simply be left off because the pack is small.

Common labelling mistakes

Ingredient list errors (most frequent issue)

• Wrong or outdated INCI names.
• Incorrect ingredient order.
• Missing declarable allergens (a growing issue as allergen requirements expand).

Missing or incorrect warnings

Label doesn't carry a warning required by the safety assessment.

Other frequent issues:

• Inconsistent Responsible Person address across label notification and PIF.
• Wrong durability method best before date used where a period after opening symbol is neededor vice versa.
• Missing country of origin on imported products.
• Omitted mandatory elements such as the batch number.

Why it matters:

The label is the most visible sign of compliance it's the first thing an inspector or marketplace checks.

These mistakes are also the most likely to be spotted.

A systematic label review against each mandatory element done before printing catches nearly all of them.

References: Regulation (EC) No 1223/2009, Article 19 and Annex VII (EUR-Lex); UK Cosmetics Regulation as retained; INCI nomenclature; OPSS guidance. General information only, not legal advice.