Cosmetic Product Labelling Requirements in the UK & EU: What Must Appear on Your Pack

Under Article 19 of the EU Cosmetics Regulation and the equivalent UK Schedule 34 requirements, every cosmetic product sold in the UK or EU must carry specific mandatory information on its label regardless of size, price point, or business stage. Missing even one required element is one of the most common (and most avoidable) reasons a product gets flagged during market surveillance. This guide walks through exactly what must appear, where, and in what form.

Why Labelling Rules Exist Separately From Your CPSR

Your CPSR proves the formula is safe to use. Labelling rules exist for a different reason entirely: to make sure the person actually holding the product in a shop or at home has everything they need to use it correctly, identify what's in it, and know who stands behind it. As the UK's retained version of Regulation 1223/2009 sets out, this labelling obligation sits alongside, not inside, your safety assessment.

The Mandatory Elements, One by One

1. Name and Address of the Responsible Person

The label must show the name and address (or registered place of business) of the Responsible Person, along with the country of origin if the product is imported from outside the EU/UK.

2. Nominal Content at the Time of Packaging

The weight or volume of the product, shown by weight or volume, except for very small quantities or free samples where alternative rules may apply.

3. Date of Minimum Durability or Period After Opening (PAO)

Products with a shelf life of 30 months or more require the PAO symbol (the open jar icon) showing how many months the product remains safe to use once opened. Products with a shorter shelf life instead require an explicit "best used before the end of" date.

4. Precautions for Use

Any specific warnings or usage instructions identified as necessary during your safety assessment must be printed clearly this is one of the direct links between your CPSR's conclusions and what actually appears on pack.

5. Batch Number or Reference for Identification

A batch code allowing the specific production run to be traced essential for recalls, complaint investigations, and linking a physical product back to its manufacturing records.

6. Function of the Product

Unless already obvious from the presentation of the product, its function must be stated (e.g. "moisturising cream," "shampoo").

7. List of Ingredients (INCI)

Every ingredient listed in descending order of weight at the time of manufacture, using standardised International Nomenclature of Cosmetic Ingredients (INCI) names, with ingredients under 1% able to appear in any order after that threshold. Fragrance and aromatic compositions can generally be listed as "parfum" or "aroma," subject to specific allergen disclosure rules for certain fragrance components above set thresholds.

Where This Information Must Physically Appear

Most mandatory information must appear on the container and the packaging. Where this genuinely isn't practical very small items, certain single-use samples some information (typically the ingredient list) may instead be provided on an accompanying leaflet, tag, or label, with a simplified indication on the pack itself referring the reader to that additional information, a flexibility explicitly built into the regulation according to CTPA's own guidance for smaller and travel-sized products.

Language Requirements

Labelling information must be in a language easily understood by consumers in the country where the product is made available, which in practice means most brands need market-specific label variants rather than a single universal pack design when selling across multiple countries with different official languages.

UK vs EU: What's Different

A product labelled correctly for the EU market is not automatically correctly labelled for the UK market, and vice versa the Responsible Person address requirement alone means most cross-border sellers need two distinct label versions, a point GOV.UK's own notification guidance reinforces when describing the separate UK registration process.

Common Labelling Mistakes

Mistake #1 — Listing ingredients in the wrong order. Descending order by weight isn't optional styling it's a specific legal requirement, and getting it wrong is easy to spot during an inspection.

Mistake #2 — Using a single label design for both UK and EU markets. The Responsible Person address alone usually forces a market-specific variant.

Mistake #3 — Omitting CPSR-identified warnings. If your safety assessor flags a specific precaution, it needs to appear on pack — this connection between CPSR and label is easy to lose track of during design finalisation.

Mistake #4 — Getting the PAO symbol wrong or omitting it entirely. This is a specific, standardised symbol with a specific meaning it isn't optional design flourish once your product's shelf life triggers the requirement.

Practical Checklist

• Confirm the Responsible Person's name and correct market-specific address appear on the label.
• Check the ingredient list is in correct descending-weight order using proper INCI names.
• Confirm the PAO symbol or minimum durability date matches your actual stability data.
• Cross-check that every CPSR-identified warning actually appears on the final pack design.
• Verify language requirements are met for every market you're selling into.
• Keep separate, correctly reviewed label versions for UK and EU sales rather than assuming one design covers both.

Frequently Asked Questions

Can I use the same label for both UK and EU sales?

Usually not without changes, since the Responsible Person address must match the correct jurisdiction, and restricted substance annexes can differ between the two systems over time.

Do I need to list every single ingredient, no matter how small the amount?

Yes, all ingredients must be listed, though those present below 1% can appear in any order after the ingredients above that threshold, which are listed in strict descending order of weight.

What if my packaging is too small to fit all the required information?

Certain information, typically the ingredient list, may instead be provided on an accompanying leaflet or tag, with a simplified reference symbol on the pack itself directing the reader to it.

Who decides what warnings need to go on my label?

Your qualified safety assessor identifies any necessary precautions or warnings as part of the CPSR process, and these must then be carried through onto the final label.

Want your label checked against your CPSR before you print? NestQual reviews cosmetic labelling alongside CPSR, PIF, and notification services, so nothing gets missed between your safety assessment and what actually ends up on pack.

Get a CPSR for your product See the Complete Compliance Pack

Sources

1. European Parliament and Council, Regulation (EC) No 1223/2009 on cosmetic products, Article 19 eur-lex.europa.eu
2. UK version, Regulation (EC) No 1223/2009, as retained in UK law legislation.gov.uk
3. GOV.UK, Submit a Cosmetic Product Notification (SCPN) gov.uk
4. Cosmetic, Toiletry and Perfumery Association (CTPA), Safety of Cosmetics ctpa.org.uk

This article is for general information and does not constitute legal advice. Always confirm current requirements for your specific product and market with a qualified safety assessor or Responsible Person.