Start with the cosmetic definition
A product is usually a cosmetic in the EU when it is intended for external contact with the skin, hair, nails, lips, teeth or mouth mainly to clean, perfume, change appearance, protect, keep in good condition or correct body odour. Handmade soap for skin, lip balm, body butter, bath salts and facial oils usually sit in this category when marketed that way.
The label requirements are only one part of the route. The product also needs a Responsible Person established in the EU, a product information file, a cosmetic safety report, good manufacturing practice, notification through CPNP, and claims that can be supported. Do not treat a finished label as proof that the product is ready for sale.
- Skin cleansing soap: usually cosmetic.
- Household cleaning soap: check chemical and detergent rules.
- Therapeutic or medical claims: may move the product out of cosmetics.
Core information on the label
Article 19 of the EU cosmetics regulation sets the main label elements. The container and any outer packaging normally need the Responsible Person name and address, country of origin for imported products, nominal content, durability information, precautions, batch number, product function where not obvious, and an ingredients list.
The information must be easy to read, visible and indelible. For tiny containers, some information can move to outer packaging, a leaflet, tag, tape or card, but the small-pack rule is not a blank permission to omit important details. Plan the label area before buying jars or tubes.
- Responsible Person name and address.
- Net weight or volume where required.
- Batch code for traceability.
- Ingredients list headed by Ingredients.
- Warnings and directions where needed.
Ingredients and INCI names
The ingredients list should use common cosmetic ingredient names, usually INCI names, and be headed by the word Ingredients. Ingredients are listed in descending order by weight at the time they are added. Ingredients below 1% may be listed in any order after the ingredients above 1%.
Fragrance is usually declared as Parfum, or Aroma for flavouring compositions, and required fragrance allergens are added as separate ingredient names when the finished product exceeds the relevant declaration threshold. Nanomaterials need the word nano in brackets after the ingredient name.
Durability, PAO and batch codes
If the product has a minimum durability of 30 months or less, the label needs a date of minimum durability, commonly shown with the hourglass symbol or words such as best used before the end of. If the minimum durability is more than 30 months, the label usually needs a period-after-opening statement, such as the open jar symbol with 6M or 12M, unless PAO is not relevant.
A batch number is separate from the expiry or PAO statement. It connects the unit in the customer's hand to your production record, raw materials, test results and any corrective action. For indie makers, a simple batch format is fine if it is consistent and recorded.
Language and market details
Some label information must be in the language required by the Member State where the product is sold. This often affects the product function, warnings, precautions and durability wording. The INCI ingredient names generally remain in the cosmetic ingredient nomenclature rather than being translated into marketing language.
If you sell the same product in several EU countries, build a label text table by market before printing. A label that works for Ireland may not be enough for France, Germany or Spain. Multilingual folding labels can be useful, but they must still be legible.
What a label generator can and cannot do
A label generator can help you assemble the required fields, keep the label structure consistent and avoid common omissions. It cannot replace the cosmetic safety report, decide whether a claim is acceptable, or confirm whether an ingredient is permitted at your exact use level.
The practical workflow is simple: finish the formula, obtain supplier documents, complete safety assessment, confirm the Responsible Person and notification route, then generate the label. When any ingredient, fragrance, packaging size or market changes, review the label again.
Frequently asked questions
Do EU cosmetic labels need an EU Responsible Person?
Yes. A cosmetic placed on the EU market must have a Responsible Person established in the EU, and the label must show that name and address.
Can I sell first and complete CPNP later?
No. EU notification is a before-market step. It is not an approval, but it must be completed before the product is placed on the EU market.
Do handmade cosmetics need INCI names?
Yes. The ingredient list should use the required common cosmetic ingredient names, usually INCI names, not kitchen names or supplier marketing names.
Is PAO required on every cosmetic?
No. It is generally used when minimum durability is more than 30 months and durability after opening is relevant. Some single-use or non-opening products may not need it.
Can I use the same label for the EU and Great Britain?
Not automatically. GB has a UK Responsible Person and SCPN route, while EU products use an EU Responsible Person and CPNP. Northern Ireland may involve EU-aligned requirements.