Introduction

According to UK and EU laws, all cosmetics marketed in these regions must be correctly labeled and packaged. Each cosmetic item must have information needed to guarantee user safety and regulatory traceability under Regulation (EC) No 1223/2009 and UK Cosmetic Regulation 2020 (SI 2020/1466).

Part of the Label and Packaging Review Service by Phoenix Safety Consultants involves an in-depth and regulation-guided assessment of your product labels and packaging to ensure that all mandatory elements, including Responsible Person details, ingredient listing and warnings, and claims are legally compliant prior to going to market.

What Is a Label and Packaging Review?

A Label and Packaging Review ensures that your cosmetic product labels meet the criteria required under Article 19 of the Cosmetics Regulation and the other associated standards like ISO 22715.

Your packaging includes both the textual and graphical elements. We assess your packaging for completeness, visibility, legibility, and durability of the information required under law.

• Legally required information presence (e.g. Responsible Person, nominal content, batch number).
• Credentials and allergen declaration on the INCI ingredient listing.
• Regulatory symbols and warning text legibility, font size and placement.
• Use of Period-After-Opening (PAO) and Best Before Date (BBE) symbols.
• Product claims appropriation in regard to CPNP and advertising.
• Compliance of multilingual labels for EU-wide distribution.

Your packaging has been assessed to ensure it is fully compliant and has the transparency required for Responsible Person approval.

Legal Requirements for Cosmetic Labels

The UK Cosmetic Regulation 2020 articulates the legal basis for Cosmetic labels contained in Article 19 of Regulation (EC) No 1223/2009. It prescribes the following mandatory requirements which must be displayed conspicuously, clearly, and indelibly at the cosmetic product container and at the external packaging:

• Responsible Person (RP) Name and Address: Must be UK or EU established business who’s liable for product compliance.
• Nominal Content: Must show weight or volume of the product excluding the weight of the packaging.
• Date of Minimum Durability or a PAO Symbol: Must show “Best before end” and/or an open-jar symbol indicating months of stability after opening.
• Batch Number or Reference Code: To enable product traceability.
• Country of Origin: Must be included for imported products.
• Function of the Product: Must be included if its function is not obvious from its presentation.
• Precautions and Warnings for Use: Must be included especially for products with restricted and/or specifically applied substances.
• Ingredient List: Must include items in the descending order of concentration using the INCI nomenclature, including allergens in Annex III.

Further requirements may involve hazard labelling that falls under the CLP Regulation (EC) No 1272/2008, or other overlapping legislation.

What We Provide

Phoenix Safety Consultants offers a structured, systematic, and validated appraisal so that you may rest assured that your label and your packagings are compliant to your needs and to the law on cosmetics, as the legislation applies.

Our offers include:

• Overall Text and Label Layout Review: Verifying the size and placement of text, the mandatory wording, and the positions of symbols, as well as claims.
• Verification of INCI and Allergens: Validation and verification of names and claims of all the ingredients and all allergen names involved as per Annex III and INCI Formatting.
• UK and EU Labelling Laws Compliance: Validation and verification as per Article 19 and its local transpositions which are applicable.
• Claims and Warnings Review: Assessment of all marketing and warning phrases, as well as a review for compliance to EU Commission Regulation (EU) No 655/2013 concerning cosmetic claims.
• Supporting Label Design (Optional): Text that is compliant and all regulatory elements for draft artwork layouts which are intended for designing the layout of the label.
• Compliance Report and Suggested Enhancements: Report that highlights and details any feedback concerning the correction and full compliance needed.

Every review is finalized in a Compliance Summary Report, which is provided in PDF format for your Product Information File (PIF) and for Responsible Person documentation.

Who Needs This Service

This service is for every organization that sells cosmetic products in the UK and EU, for example:

• Cosmetic and Personal-Care Brands creating new product lines.
• Private-Label and White-Label Manufacturers supplying compliant products under third-party branding.
• Importers and Distributors relabelling non-EU cosmetics for UK or EU sale.
• Regulatory and Quality Managers responsible for documentation and audit compliance.
• Start-ups and SMEs needing professional verification before Responsible Person submission.

Whether you're getting ready to enter the market or updating labels after a formula has changed, this review guarantees your product is legally compliant and your customers know what they are getting.

Common Non-Compliances Detected

Cosmetic labelling non-conformities rank as one of the most common triggers for product withdrawals across the UK and EU markets. In our reviews, we most commonly find:

• Incomplete or Missing Responsible Person details.
• Ingredients listed improperly or non-listed INCI ingredients.
• No Mandatory allergen disclosure for fragrance ingredients.
• Missing or Improper PAO or best-before symbols.
• Violating Regulation (EU) No 655/2013 and making Non-compliant claims (e.g. “hypoallergenic,” “chemical-free”).
• Abnormally small Font sizes breaking Legibility rules.
• Missing a batch code or country of origin.

Proactively addressing these issues during the review phase eliminates the possibility of enforcement actions, border detentions, and recall orders.

Process and Turnaround

Our review process for labels and packaging focuses on both efficiency and accuracy.

Step 1: Submission Clients send us digital drafts or artworks (AI, PDF, or image), ingredient lists, and product descriptions.
Step 2: Regulatory Assessment Our assessors consider labels and texts for the layout comparing them for the UK Cosmetic Regulation 2020 and the Regulation (EC) No 1223/2009 and ISO 22715.
Step 3: Report Preparation A detailed written compliance report is drafted for the client expressing each element’s conformity level and corrections required.
Step 4: Review and Follow-Up Clients can request a review session and discuss the report, or we execute the recommendations directly on the revised artworks.

Turnaround is between 2 and 4 working days on average, depending on the number of SKUs or reviewed languages. A same-day review is available on request.

Pricing and Deliverables

Indicative Pricing

• Single Product Label Review: £20 – £50
• Review Multi-Variant or Multi-Language Labels: £50 – £100
• Optional Label Design Integration: Quoted separately depending on complexity.

Deliverables

• Regulatory Compliance Report (PDF): Compliance with Article 19 and its UK equivalents.
• Summary of Label Layout Verification: Validation of symbol and placement guidance.
• Product Information File (PIF) Checklist: For the Responsible Person.
• Amendment Approval: Given after all necessary changes are made.

All documents are integrated into the PIF and are ready for audits or inspections by Competent Authorities.

Before you launch your brand, check that your Cosmetic product labels and packaging meet the legal requirements. Correct labelling helps consumer protection, and transparency, and shows the brand’s integrity to the regulators.

Make sure that your labels and packaging abide by all UK and EU legal requirements before you launch. For thorough final review before release, send your draft to Phoenix Safety Consultants.

→ Submit Label for Review
→ Learn More About CPSR and PIF Services
→ Explore UK and EU Cosmetic Compliance Support