EU Cosmetic Labeling Requirements: What Must Appear on Your Packaging
EU Cosmetics Regulation 1223/2009 (and its UK equivalent, the UK Cosmetics Regulation) is one of the most detailed product labeling regimes in the world. Non-compliance can result in product withdrawal from the market, significant fines, and damage to brand credibility.
This guide covers every mandatory labeling element for cosmetic products sold in the EU and (separately) in Great Britain post-Brexit.
Mandatory Label Elements Under EU Cosmetics Regulation
1. Name and Address of the Responsible Person
The Responsible Person (RP) is the entity (company or individual) established in the EU who is legally responsible for the product's compliance. The RP's name and address must appear on the packaging. For non-EU brands entering the EU market, a Responsible Person must be appointed before the product is placed on the EU market.
2. Nominal Content by Weight or Volume
The net quantity (weight or volume) at the time of packaging, in metric units. The minimum character height varies by total net quantity: under 50ml — no minimum; 50ml to 200g — 2mm; 200g to 1kg — 3mm; over 1kg — 4mm.
3. Date of Minimum Durability (PAO Symbol)
If the cosmetic has a shelf life of 30 months or less: a 'best before' date using the hourglass symbol or the wording 'Best used before end:' followed by the date (month/year).
If the cosmetic has a shelf life exceeding 30 months: a Period After Opening (PAO) symbol — an open jar icon with the number of months after opening during which the product can be used safely (e.g., '12M' means safe for 12 months after first opening).
4. Precautionary Information
Any special precautions for use that consumers need to know to use the product safely. For hair dyes: mandatory warnings about allergic reactions and the patch test requirement. For self-tanning products: UV sensitivity warnings. For products containing hydrogen peroxide: concentration warnings.
5. Batch Number
A batch number (or reference enabling identification of the batch of manufactured goods) must appear on the packaging. The wording 'Batch:' or 'Lot:' followed by the batch code is the common format.
6. Function of the Product
The function of the cosmetic product must be stated unless it is clear from the product presentation. For example, 'Face Moisturiser', 'Body Lotion', 'Cleansing Shampoo'.
7. List of Ingredients (INCI List)
The full ingredient list using INCI (International Nomenclature of Cosmetic Ingredients) names, preceded by the word 'Ingredients:'. Rules:
- Listed in descending order of weight at time of inclusion (ingredients present at 1% or less may be listed in any order after all ingredients above 1%)
- Colourants may be listed at the end using CI (Colour Index) numbers
- Fragrance/perfume components listed as 'Parfum' (EU) or 'Fragrance' (US) unless individual allergens are above 0.001% in leave-on products or 0.01% in rinse-off products, in which case they must be declared individually (Regulation 2023/1545)
- Nano-ingredients must be identified with '[nano]' after the INCI name
8. Country of Origin (If Not EU)
Where a cosmetic is manufactured outside the EU, the country of origin must appear on the label.
UK Cosmetics Regulation Post-Brexit
From January 2021, cosmetic products placed on the Great Britain (England, Scotland, Wales) market must comply with the UK Cosmetics Regulation (retained from EU law). Key differences from EU:
- The Responsible Person must be established in Great Britain (a UK RP is needed for GB, a separate EU RP is needed for the EU market)
- UK-specific address format for the RP
- Products sold in Northern Ireland continue to be governed by EU cosmetics law (NI Protocol/Windsor Framework)
For brands selling into both GB and EU markets, dual-RP arrangements and dual-language labeling are required.
Design Tips for Cosmetic Compliance Labels
Minimum type sizes: All mandatory text must be legible. EU guidance suggests minimum 7pt for standard packaging; smaller only where space genuinely cannot accommodate it.
Indelible print: Mandatory information must be indelibly marked on the packaging. Foil stamping and embossing without ink are not acceptable for mandatory information.
Multi-language panels: Products sold across multiple EU markets require mandatory information in all languages of the target member states. A Danish brand selling into Germany, France, and the Netherlands needs German, French, and Dutch labeling.
Durable labeling: The label must remain readable throughout the product's shelf life under normal storage conditions.
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