Understanding UK Cosmetic Labelling Requirements

By Dr. Helena Vos, Regulations & Ethics | International Institute of Beauty

Cosmetic products have become an integral part of daily life, ranging from skincare and haircare to fragrances and colour cosmetics. In the United Kingdom, cosmetic labelling is governed by detailed legislation designed to protect consumers, ensure transparency, and foster trust in the beauty industry.

For manufacturers, distributors, and retailers, understanding and complying with these labelling requirements is critical not only to meet legal obligations but also to maintain consumer confidence in an increasingly discerning marketplace.

This article offers a comprehensive overview of the UK’s cosmetic labelling regulations, explores their legal foundation post Brexit, highlights the key mandatory elements, and considers how these requirements align with global standards.

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Legal Framework Governing Cosmetic Labelling in the UK

Following the United Kingdom’s departure from the European Union, the UK has retained many of the EU’s stringent cosmetic regulations but with some modifications. The primary legislation governing cosmetic products and labelling in the UK includes:

• The UK Cosmetics Regulation (The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019): This legislation transposes the EU Cosmetics Regulation (EC) No 1223/2009 into UK law, with specific provisions adapted for Great Britain.

• The UK REACH Regulation: Governs the registration and safe use of chemicals in cosmetics and other products.

• The UK Consumer Protection from Unfair Trading Regulations 2008: Addresses misleading claims and advertising.

  
  

Northern Ireland, due to the Northern Ireland Protocol, continues to follow the EU Cosmetics Regulation directly, creating a unique dual regulatory landscape within the UK.

Mandatory Labelling Requirements for Cosmetic Products

To be legally placed on the UK market, cosmetic products must feature labels containing precise information presented clearly and legibly. The key mandatory elements include:

1. Product Identity

The label must specify the product’s function, such as “moisturising cream” or “hair conditioner,” unless this is obvious from its presentation.

2. Ingredients List

Ingredients must be listed in descending order of weight at the time of formulation, using the International Nomenclature of Cosmetic Ingredients (INCI) names. This list is essential for consumers with allergies or sensitivities and for regulatory scrutiny.

3. Nominal Quantity

The quantity of the product, typically in grams or millilitres, must be indicated, except for single use packages.

4. Expiry Date and Period After Opening (PAO)

• Expiry Date (Best before end): Required if the product’s shelf life is 30 months or less, indicated by a symbol of an open jar with the number of months inside (e.g., 12M for 12 months).

• PAO: For products with a shelf life exceeding 30 months, the label must show how long the product remains safe after opening.

  
  

5. Precautions for Use

If applicable, labels must include special precautions for safe use, such as warnings or directions for certain skin types or usage conditions.

6. Manufacturer or Responsible Person

The name and address of the manufacturer or the UK Responsible Person must be clearly indicated. This entity assumes legal responsibility for the product on the UK market.

7. Batch Number

A batch or lot number is required for traceability, allowing identification of the product’s manufacturing run.

Additional Labelling Considerations

Language Requirements

Labelling information must be provided in English for products marketed in Great Britain. In Northern Ireland, labels often include both English and Irish or English and Welsh, reflecting local regulations.

Claims and Marketing Statements

Any claims made on the packaging must be truthful, substantiated, and not misleading. Examples include “hypoallergenic,” “dermatologically tested,” or “organic.” These claims are subject to strict scrutiny under the UK Consumer Protection from Unfair Trading Regulations 2008.

Environmental and Ethical Labelling

Although not strictly mandated by law, sustainability claims such as “recyclable packaging” or “cruelty free” are increasingly prevalent. Brands must ensure these statements are accurate to avoid accusations of “greenwashing.”

Post Brexit Regulatory Landscape and Its Implications

Brexit has introduced nuances into the UK cosmetics market. Companies must now navigate separate regulatory requirements for Great Britain and Northern Ireland:

• Great Britain (England, Scotland, Wales): Products must comply with the UK Cosmetics Regulation. Notification of cosmetic products to the UK Office for Product Safety and Standards (OPSS) is mandatory before market launch.

• Northern Ireland: Cosmetics remain regulated under EU law, and products must be registered with the EU’s Cosmetic Products Notification Portal (CPNP).

  
  

This dual regime requires businesses to carefully manage product formulations, labelling, and regulatory notifications to ensure compliance in each jurisdiction.

Alignment with Global Standards

UK cosmetic labelling requirements closely mirror those of the European Union, which itself aligns broadly with international standards such as those of the International Cooperation on Cosmetics Regulation (ICCR).

This alignment facilitates market access and regulatory harmonisation, which is essential for global brands operating across multiple territories.

Nevertheless, slight differences remain between jurisdictions. For example, ingredient restrictions and labelling nuances in the US or Asia Pacific markets may vary, requiring tailored approaches to compliance and product communication.

Challenges and Best Practices

Navigating Complexity

The evolving regulatory environment demands meticulous attention to detail. The complexity of dual UK EU compliance post Brexit can be challenging, particularly for small and medium sized enterprises (SMEs) lacking dedicated regulatory teams.

Ensuring Transparency and Consumer Safety

Clear, accurate labelling fosters consumer trust and ensures safety, especially for those with allergies or sensitivities. Compliance with labelling laws is not merely a legal obligation but a cornerstone of ethical business practice.

Leveraging Technology

Many companies now employ digital tools and databases to manage ingredient information, regulatory updates, and labelling requirements efficiently. Staying current with legislative changes is vital to avoid costly recalls or penalties.

Final Thoughts

Understanding and adhering to UK cosmetic labelling requirements is fundamental for all stakeholders in the beauty industry. While the post Brexit regulatory framework presents challenges, it also offers an opportunity for brands to demonstrate commitment to transparency, safety, and consumer protection.

As the UK continues to develop its regulatory landscape, ongoing vigilance, education, and collaboration with regulatory authorities will be essential.

By doing so, the industry can maintain high standards and continue to thrive in a competitive, globally connected market. key to navigating this complex and dynamic landscape.