Why cosmetic labelling is a legal requirement

If you make and sell cosmetics or toiletries in the UK, your label is more than branding. It is a legal document. Under the UK Cosmetics Regulation, every product placed on the market must carry a defined set of information so that customers can use it safely and so that regulators can trace it if something goes wrong. This applies whether you are selling handmade soap at a weekend market, a facial oil through your own website, or a full skincare range into independent shops.

Responsibility sits with the "responsible person" — usually the manufacturer, the importer, or a UK-based business you appoint to act on your behalf. They must keep a product information file and hold records for ten years after the last batch is placed on the market. Your label is the public face of that paperwork, so it pays to get it right from the first print run.

The ingredient list: names, order and thresholds

Every cosmetic product sold in the UK needs an ingredient list, introduced by the word Ingredients. The names must be the INCI (International Nomenclature of Cosmetic Ingredients) names, not your own friendly descriptions. That means Aqua rather than "spring water", and Butyrospermum Parkii Butter rather than "shea butter".

• List ingredients in descending order of weight at the time they are added, down to 1%.
• Anything present at less than 1% may be listed in any order after the 1% ingredients.
• Colourants can be listed in any order at the end, using their CI numbers, often preceded by "may contain".
• Any nanomaterial must have the word "(nano)" after its name.
• Certain fragrance allergens must be declared individually when they exceed the legal threshold — lower for leave-on products, higher for rinse-off.

A common mistake is forgetting that impurities and carry-over from raw materials are not listed, but anything intentionally added is. Recipe changes mean new artwork, so keep a version history of every label you approve.

Batch codes: small print with a big job

Every cosmetic product must carry a batch number or code so it can be identified if a problem arises. It does not need to be readable by your customers as a date, but it must allow you to trace the product back to a specific production run. A simple system works well: two digits for the year, two for the month, and a run number, for example 2503-02 for the second batch made in March 2025.

Print or stamp the batch code somewhere it will not rub off in use — the base of a jar, the crimp of a tube, or the bottom edge of a carton. If you outsource filling, agree in writing whose code goes on the pack and keep a record that links it to your own files.

PAO symbols, durability dates and shelf life

There are two systems, and choosing the right one depends on how long your product lasts.

• Long shelf life (over 30 months): use the PAO symbol — an open jar with a number and "M" inside, such as 12M or 24M. This tells the customer how long the product is safe to use after opening. You still need to know and be able to justify that figure with stability testing.
• Short shelf life (30 months or less): show the date of minimum durability, either as "Best before" followed by the date, or with the hourglass symbol and the date. No PAO symbol is needed in this case.

Be realistic. A water-based cream preserved with a gentle system will not last as long as an anhydrous balm, and customers will hold you to whatever your label promises.

Responsible person details and other must-haves

Alongside the ingredient list, every label needs a few other essentials. The name and address of the responsible person must be shown, and for products sold in Great Britain that address must be in the UK. If you sell into Northern Ireland, an EU or UK address is acceptable, but it is worth checking the current rules before you print.

• Nominal content at the time of packaging, shown as weight or volume, unless the product is very small or a single-use sample.
• Any warnings and precautions for use, such as "avoid contact with eyes" or "discontinue if irritation occurs".
• The function of the product, unless it is obvious from the name or presentation.
• Country of origin if the product is made outside the UK.

All of this must be in English, legible and indelible. Tiny text on a busy background is the most common reason labels fail a spot check.

Practical tips for beautiful, compliant labels

You can have a label that is both attractive and fully compliant. Design the panel around the legal text rather than squeezing it in at the end, and give the ingredient list a clear block with good contrast. Keep a minimum text size that stays readable on a 50ml bottle — if in doubt, print a sample and check it in dim light.

Choose materials that suit the product: oil-resistant stocks for balms, waterproof film for anything used in the shower, and adhesives that hold on curved or recycled surfaces. Order a small proof run before committing to thousands of labels, and have a second pair of eyes check every claim, allergen and batch field. A little care at the artwork stage saves a very expensive reprint later.