What Has to Be on a Cosmetics Label in the UK and EU?

A cosmetics label in the UK and the EU has to carry 7 items from Article 19 of Regulation (EC) No 1223/2009: the responsible person’s name and address, the nominal content, a durability date or period after opening, precautions, the batch number, the product function and the ingredient list. Great Britain adds a UK responsible person and English text.

One regulation, two versions

Cosmetics sold in the EU and in Great Britain are labelled under the same text, Regulation (EC) No 1223/2009. The EU applies its own version. Great Britain, which is England, Scotland and Wales, applies the regulation as amended after 2020, and the government explains it in its guidance for Great Britain. Northern Ireland has separate guidance.

For a brand owner this is good news. The list of what goes on the pack is in Article 19 in both versions, and most of the wording is identical. A label that is planned well for one market needs only a few changes for the other, and those changes can be designed in from the start.

Both versions open with the same requirement. The container and the packaging must carry the information “in indelible, easily legible and visible lettering”. For the design that means print that does not rub off in a wet bathroom, a floor for type size and contrast, and no text hidden under a fold. Our article on hair care packaging that stays readable in the shower looks at the wet bathroom case.

This article covers what the label has to say and where it has to sit. It does not cover the product file, the safety report or notification, which belong to the responsible person. If you are adding a market to an existing range, our guide to what changes on the label in a second market is the companion piece.

The 7 items Article 19 puts on the pack

Article 19 lists 7 points, lettered (a) to (g). In plain terms they are:

• The name and address of the responsible person, and the country of origin for imported products.
• The nominal content at the time of packaging, by weight or by volume.
• The date of minimum durability, or the period after opening for longer-lasting products.
• Particular precautions to be observed in use.
• The batch number or a reference that identifies the product.
• The function of the product, unless it is clear from its presentation.
• The list of ingredients.

The default is that each item appears on both the container and the outer packaging. The GOV.UK guidance says so directly for the name and address: “The information must be given on both the container and the outer packaging.” Article 19 then makes specific allowances. The ingredient list may be given on the packaging alone, and a batch number may appear only on the packaging when the product is too small to carry it.

The table below sets out each item with where it sits and what differs in Great Britain.

The responsible person and the country of origin

The first item is the one that differs most between the 2 markets. Article 19 asks for the name or registered name and the address of the responsible person. The details may be abbreviated as long as the person and the address can still be identified.

For Great Britain, the guidance states that “a cosmetic product cannot be placed on the GB market unless there is a Responsible Person established in the UK in respect of that cosmetic product”. The name and address on the label are those of that UK-based person.

There is a transition, and it has an end date. For a period of seven years, until 31 December 2027, the name, address and country of origin requirements are satisfied in Great Britain if the label complies with the EU version of the same point, which means it shows a responsible person based in the EU or EEA. A label that carries only an EU address today has a deadline, and the artwork should be changed before stock printed for 2028 is ordered.

The country of origin is the second part of the point. The guidance says: “The country of origin must be specified for imported cosmetic products, including products imported from the EU.” It adds that Made in the EU is not accepted as the country of origin, because the EU is not a country.

For the layout, plan one address block that can hold 2 addresses. If several addresses are listed, the one where the product information file is kept has to be highlighted.

Content, dates and the 2 symbols

The nominal content is given by weight or by volume. Article 19 exempts packaging containing less than five grams or five millilitres, free samples and single-application packs. In Great Britain the guidance adds that the UK Weights and Measures (Packaged Goods) Regulations 2006 must also be met, so the declared quantity is a legal statement as well as a line of type.

The date rule turns on 30 months. A product with a minimum durability of 30 months or less carries a date of minimum durability, introduced by the hourglass symbol or the words best used before the end of. The date is the month and year, or the day, month and year, in that order. The guidance gives accepted formats: “Best before November 2010, Best before Nov 10 and Best before 11/10 are all acceptable forms.”

A product that lasts more than 30 months does not need the date. It carries the period after opening instead, shown by the open jar symbol with a number of months or years, such as 12 m.

Two things follow for the design:

• A date changes with every batch, so it is applied on the filling line. The artwork needs a clear, unprinted or lightly printed area for it.
• The open jar symbol is printed with the artwork. It should be drawn at a size where the number inside it can still be read, which on a small tube often decides the height of the whole information block.

The ingredient list

The ingredient list is the longest block of text on most cosmetic packs, and Article 19 is specific about its form.

• It is preceded by the word ingredients.
• The order is set: “The list of ingredients shall be established in descending order of weight of the ingredients at the time they are added to the cosmetic product.”
• Ingredients in concentrations of less than 1 % may be listed in any order after the others.
• Perfume and aromatic compositions are referred to by the terms parfum or aroma.
• An ingredient present as a nanomaterial is followed by the word nano in brackets.
• Names come from the common ingredient glossary referred to in the regulation.

Decorative cosmetics sold in several colour shades get a practical allowance. All the colourants used in the range may be listed on one label, provided the words may contain or the symbol +/- are added.

The list may be given on the packaging alone. For a small container this is the rule that makes the design possible: the list moves to the carton, and the container keeps the items that have to stay on it.

The order and the names come from the formula, so the list is supplied by the manufacturer or the responsible person. It should be set exactly as supplied, never edited or reordered. For type size, our article on how small type can be on packaging gives the working limits.

Which language does the label need?

Language is the second place where the 2 markets differ.

In Great Britain the guidance asks for English. The minimum durability date, the precautions and the function of the product each have to appear in English on both the primary container and the outer packaging. Other languages may sit beside it: “The additional presence of this information in other languages is not prohibited.”

In the EU the regulation leaves the choice to each country. For the content, the date, the precautions and the function, the language “shall be determined by the law of the Member States in which the product is made available to the end user”. A pack sold in 3 EU countries may therefore need 3 languages for those lines, and the responsible person confirms which.

The ingredient list is the exception that helps. It uses the common ingredient names, so it is written once and does not have to be translated.

Plan the languages before the layout is drawn. One multi-language pack keeps stock simple and needs the most space. One pack per market, with a shared front and a back panel that changes, needs more artwork files and less space. The name needs the same planning: see choosing a product brand name for more than one country.

Symbols help in every case. The hourglass, the open jar and the hand and book symbol say the same thing in every language.

When the pack is too small for all of it

Article 19 accepts that not every pack has room. Where it is impossible for practical reasons to print the precautions or the ingredient list as required, the information goes on an enclosed or attached leaflet, label, tape, tag or card. The pack then carries abbreviated information or the hand and book symbol, which tells the buyer to look for it.

Before reaching for a leaflet, work through the layout in this order:

• Move the ingredient list to the carton, since the packaging alone is allowed.
• Set the address block in its abbreviated form.
• Use the symbols in place of the words they replace.
• Check that the barcode is at the smallest size that still scans. Our guide to barcode colours and size explains the limits.
• Only then add a leaflet, a tag or a peel-back label.

Marketing text is not on the Article 19 list, and it competes for the same space. If the pack also carries environmental statements, they have their own rules, which we cover in green claims by market.

Working with MarkaWorks on a cosmetics label

We design cosmetics and skincare packaging as a regular part of our work, and our cosmetics and skincare projects page lists 15 case studies. In this category the pack has to hold ingredient lists at small type sizes, and it usually has secondary packaging, so the label and the carton are planned together.

The division of work is clear. Your responsible person or regulatory adviser confirms the wording: the address, the precautions, the ingredient list and the languages. We design the pack so that all of it fits, stays readable and still looks like your brand. In practice that means 4 things in our packaging and product design work:

• One information block with a fixed order, used on every product in the range, so a new product needs new text and no new layout.
• Space planned for a second address and for a second language before the first print run.
• A clear area for the batch code and the date on every container.
• Production artwork drawn on your production partner’s dieline, with the working files handed over.

If you are preparing a cosmetics range for the UK, the EU or both, you can work with us on the packaging. Send us your product list and the markets you plan to sell in, and we will show you how we would lay out the label and the carton.

Questions brand owners ask about cosmetics labels

Can one label be used for both the UK and the EU?

Often, yes. Article 19 lists the same 7 items in both versions. The label needs a responsible person address valid for each market, the country of origin for imported products, and English for Great Britain alongside the languages required by each EU country where the product is sold.

Until when can a label show only an EU responsible person in Great Britain?

Until 31 December 2027. The GOV.UK guidance describes a seven-year period during which the name, address and country of origin requirements are satisfied if the label complies with the EU version of Article 19(1)(a). After that date the label needs the UK responsible person.

Does the ingredient list have to be on the bottle?

No. Article 19 says the list of ingredients may be indicated on the packaging alone. If the product is sold without outer packaging, the container is the packaging, so the list has to appear there or on an attached leaflet, label, tape, tag or card.

When is a period after opening symbol needed?

When the product has a minimum durability of more than 30 months. In that case a best before date is not mandatory, and the pack carries the open jar symbol with the period in months or years, for example 12 m, on the container and the outer packaging.