The short answer
A compliant cosmetic label carries the Responsible Person's name and address, country of origin for imports, the nominal quantity, the date of minimum durability or period after opening, the precautions for use including those the safety assessor requires, the batch number, the function, and the ingredient list in INCI descending order with allergens named, all in the required language and legible. A label review checks each of these against the regulation and against Part B of the CPSR before you print.
Key takeaways
- Most label failures are not exotic; they are missing or misplaced mandatory elements, INCI lists in the wrong order and allergens not named.
- The label must agree with the CPSR: the ingredient list with Part A and the warnings with Part B.
- Claims are part of the label review because a medicinal or unsubstantiated claim on the pack is a labelling breach.
- Container and outer packaging have different requirements; know what must be on each.
- Review before print; reprints are the most common avoidable compliance cost.
Article 19 of Regulation (EC) No 1223/2009 sets out what a cosmetic label must carry, and the Cosmetic Products Enforcement Regulations 2013 make the same requirements enforceable in Great Britain. The list is short and the rules are old, yet labels remain the most frequent finding when the Office for Product Safety and Standards or Trading Standards inspect small brands, because the elements interact with the safety report, the notification and the marketing in ways that a designer working from a brief does not see.
This guide sets out the fourteen point review Phoenix runs on every label before print: the mandatory elements, how each is commonly got wrong, how the label must agree with the CPSR, and the claims and language checks that complete it. Use it as your own pre print checklist, or as a description of what our label and packaging review does for you.
Before the checklist: container versus outer packaging
The regulation distinguishes the container, the immediate pack holding the product, from the packaging, the outer box or carton. Most mandatory information must appear on both. The ingredient list may appear on the outer packaging only, and where there is no outer packaging it must be on the container, on an attached label, tag or card, or in a leaflet indicated by the hand and book symbol on the container. The batch number may appear on the packaging only where the container is too small. Knowing which surface each element belongs on is the first step, because a beautiful box carrying everything and a bare jar carrying nothing is non compliant the moment the box is thrown away.
The fourteen checks
1. Responsible Person name and address
The name or registered name and the address of the Responsible Person, on both container and packaging, abbreviated only so far as the person remains identifiable. For Great Britain the RP must be established in the UK; for the EU, in the EU. Dual market products usually carry both. A brand name without a legal name and postal address fails; a website alone fails.
2. Country of origin for imports
Where the product is imported from outside the market, the country of origin must be stated. Made in followed by the country satisfies it.
3. Nominal quantity
The content at the time of packaging by weight or volume in metric units, on both container and packaging, except for packs under five grams or five millilitres, free samples and single application packs. The e mark may be added only if the packaged goods weights and measures requirements are met.
4. Date of minimum durability or period after opening
Products with a durability of thirty months or less carry a best before end date preceded by the hourglass symbol or the words, with the storage conditions needed to achieve it. Products with a durability over thirty months carry the open jar symbol with the period after opening in months. Getting this wrong in either direction is common: an anhydrous balm with a long shelf life carrying a best before date, or a water based product with an eighteen month life carrying a PAO. The choice follows from the stability conclusion in the CPSR.
5. Precautions for use
The particular precautions the regulation's annexes require for specific ingredients, and every warning and instruction the safety assessor specified in Part B, on both container and packaging, or in a leaflet with the hand and book symbol where space is limited. This is the check most tightly bound to the CPSR: the label must carry exactly what Part B says. Avoid contact with eyes, keep out of reach of children, discontinue if irritation occurs, not for children under three, the sun exposure statement for exfoliating acids and the professional use statement are the usual items.
6. Batch number
The batch number or reference identifying the product, on both, or on the packaging only where the container is too small. Without it, traceability and recall are impossible, and it is the element small makers most often omit from the container.
7. Function
The function of the product, unless it is clear from the presentation. Body butter, shampoo and lip balm are self evident; a product called Glow or Serum No. 3 needs a function statement.
8. Ingredient list heading and order
Headed Ingredients, listing ingredients in descending order of weight at the time of addition, with ingredients at one percent or less listed in any order after those above one percent, colourants listed in any order after the others by CI number, and, for decorative cosmetics in several shades, all colourants used in the range with the may contain symbol. The list follows from the Part A formula; a list built from the recipe rather than the assessed formula is a frequent mismatch.
9. INCI nomenclature
Ingredients named by their INCI names, with water as Aqua, fragrance and flavour as Parfum and Aroma, and botanicals by their Latin binomials. Common names, trade names and marketing descriptions in the ingredient list fail.
10. Allergen declaration
The fragrance allergens on the regulation's list present above the labelling thresholds, one part in a thousand in rinse off products and one in ten thousand in leave on, named individually in the list. The list of declarable allergens has been substantially expanded in the EU with transition dates, and Great Britain's position differs, so a dual market label may need the longer list. The declaration follows from the constituent data in the CPSR. Our allergen compliance review produces it from the fragrance documents.
11. Nano and other special designations
Ingredients present as nanomaterials followed by nano in brackets; ingredients subject to specific labelling under the annexes flagged as required.
12. Claims
Every claim on the label checked against the common criteria of legality, truthfulness, evidential support, honesty, fairness and informed decision making, and against the assessment: nothing medicinal, nothing the CPSR did not consider, nothing implying an ingredient is absent when it is legally required to be so, and free from claims only where they meet the criteria. A medicinal claim on a cosmetic label is not just a marketing issue; it can take the product outside the regulation altogether.
13. Language and legibility
Mandatory information in the language required by the country of sale, indelible, easily legible and visible. English satisfies Great Britain; each EU country sets its own requirement, and multi language packs must fit every market's text at a legible size. Metallic ink on a dark jar and six point type on a curved tube are the usual legibility failures.
14. Symbols used correctly
The open jar for period after opening with the period inside or beside it, the hourglass for date of minimum durability, the hand and book to indicate enclosed or attached information, the e mark only where earned. Recycling and EPR marks as required by packaging waste rules. Decorative badges implying certification or approval that does not exist removed.
The label and the CPSR must agree
Three points of the review are cross checks against the safety report rather than the regulation alone. The ingredient list must match the Part A formula in content and order. The warnings must match Part B exactly. The claims must be consistent with the assessment. A label that passes every regulatory element but carries a warning Part B did not require, omits one it did, or lists an ingredient the assessor never saw, is a label for a different product. Our guides to Part A and Part B show where each element comes from. Confirming that every cosmetic ingredient on the pack appears under its correct INCI name, and in the right order, is one of the simplest ways to catch this kind of mismatch before it reaches a shelf.
Small containers and the leaflet symbol
Lip balm tubes, sample pots and rollerballs cannot carry everything. The regulation allows the ingredient list and the precautions to appear on a leaflet, label, tape, tag or card enclosed with or attached to the product where it is impracticable to put them on the container, indicated by the hand and book symbol on the container, and allows the batch number to appear on the packaging only. It does not allow the Responsible Person, nominal quantity or durability to be moved off the container except in the smallest packs. A peel back label, a fold out label or a tie on tag are the practical solutions, and they must survive to the point of sale. These different container types each raise their own practical challenges, but the underlying cosmetic labelling requirements, including the period after opening symbol where it applies, do not change because the pack is small.
Online listings are labels too
The regulation's labelling rules apply to the product and its packaging, but consumer protection law and the claims criteria apply equally to product pages, marketplace listings and social posts, and enforcement increasingly starts online because it is easy to inspect. A label that passes the fourteen checks can be undermined by a product page that calls the cream healing, claims it is chemical free, omits the ingredient list where distance selling rules require it to be available before purchase, or shows an old artwork with different allergens. Run the claims and ingredient checks on the listing as well as the pack, and keep the two in step when either changes. A listing that omits a required warning such as avoid contact with eyes, when the physical label carries it, is just as much a compliance gap as an inconsistency on the pack itself.
Multi market labels
Brands selling in Great Britain and the EU face a choice between one label carrying both markets' requirements and separate labels. A combined label needs both Responsible Person addresses, the longer of the two allergen lists during divergence, and every required language for the countries of sale, which quickly exhausts space on small containers and pushes information to leaflets or outer packaging. Separate labels are simpler individually but double the artwork to maintain. Either way, Northern Ireland follows EU requirements. Brands working across both the UK Cosmetics Regulation and its EU counterpart need to track divergence carefully, since a label compliant under one may fall short of the other. Getting this wrong is also what tends to drive a product recall, since mislabelled stock already on shelves in multiple markets is far harder to correct than a listing caught before sale, and the same care applies to any personal care products sold alongside cosmetics under a shared brand. Our guide to dual market CPSRs covers the assessment side of the same decision.
Common failures we see
- Brand name and website but no legal name and address.
- INCI list from the recipe, not the assessed formula, in the wrong order.
- Allergens not named because the fragrance was treated as Parfum alone.
- PAO on a product that needed a best before date, or the reverse.
- Part B warnings missing or paraphrased.
- No batch number on the container.
- Medicinal or absent ingredient claims.
- English only on packs sold into the EU.
- Illegible type or ink.
- Certification style badges.
How to run the review
- Print the artwork at actual size. Legibility cannot be judged on screen.
- Lay Part A and Part B beside it. Check the ingredient list against A1 and the warnings against B2.
- Walk the fourteen points for the container, then for the packaging.
- Check every claim on the pack, and then the website, against the criteria and the assessment.
- Confirm the language for each market and the RP for each market.
- Sign off, date the artwork and file it in section one of the PIF.
Phoenix runs exactly this review as a label and packaging review on artwork before print, and it is included in the all in one compliance pack so the label is checked against the report by the people who wrote it.
Official sources and legislation
About the author
Phoenix Safety Consultants is a cosmetic compliance consultancy with offices in London, Estonia and Pensacola, Florida. Our safety assessors and toxicologists prepare Cosmetic Product Safety Reports, Toxicological Risk Assessments, Product Information Files, Safety Data Sheets and UK and EU notifications for brands of every size. Talk to the team on WhatsApp at +44 7346 009332 or at Compliance@phoenixcosmeticsafety.com.
Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.
Frequently Asked Questions
What must be on a cosmetic label in the UK?
The Responsible Person's name and address, country of origin for imports, nominal quantity, date of minimum durability or period after opening, precautions for use including those in the CPSR, batch number, function and the INCI ingredient list with allergens named, in English, legible and indelible.
Does the ingredient list have to be on the container?
It may appear on the outer packaging only. Where there is no outer packaging it goes on the container, an attached label, tag or card, or a leaflet indicated by the hand and book symbol.
How do I know whether to use a PAO or a best before date?
Products with a durability of thirty months or less carry a best before date with the hourglass; products with longer durability carry the open jar period after opening symbol. The stability conclusion in the CPSR determines which.
Which fragrance allergens must be named on a cosmetic label?
Those on the regulation's allergen list present above one part in a thousand in rinse off or one in ten thousand in leave on products, named individually. The EU list has been expanded with transition dates and Great Britain's position differs.
Why must the label match the CPSR?
Because the ingredient list must reflect the formula assessed in Part A and the warnings must be those required in Part B. A label that differs describes a product other than the one assessed.
Can I put a compliance badge on my cosmetic label?
No badge is recognised by the regulation, and badges implying certification or approval that does not exist can be misleading claims. Use the required symbols only.
What happens if my label is non compliant?
Trading Standards can require correction, withdrawal or recall, marketplaces can delist, and the product is technically non compliant even if the CPSR is perfect. Reprints are the most common avoidable compliance cost, which is why the review happens before print.
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