Cosmetic Product Compliance Guide (UK Regulations)

This page summarises UK trading standards requirements for cosmetic products under assimilated Regulation (EC) No 1223/2009 and related legislation. It is for general guidance only and does not constitute legal advice. For the full official guidance, see Business Companion – Cosmetic Products.

What is a Cosmetic Product?

Under assimilated Regulation (EC) No 1223/2009, a cosmetic product is defined as any substance or mixture intended for external contact with the human body — such as the skin, hair, nails, lips, or teeth — with the primary purpose of cleaning, perfuming, changing appearance, protecting, or keeping these parts in good condition.

This definition covers cosmetic products only — it does not extend to medicinal products, medical devices, or biocides.

A cosmetic product must not be swallowed, inhaled, injected, or implanted into the body. If a product is intended for any of these uses, it does not qualify as a cosmetic and falls outside this regulation.

About Aromatherapy Products

Aromatherapy items may be classed as medicines, cosmetics, or neither, depending entirely on how they are meant to be used. Their governing rules differ accordingly — some fall under the General Product Safety Regulations 2005. Businesses unsure of the correct classification should consult their local Trading Standards service.

Key Legal Points to Remember

It is a criminal offence to sell a cosmetic product that is:

• Incorrectly labelled, or
• Missing required information about the manufacturer or importer, ingredients, durability, function, or safety precautions

It is also an offence to fail to carry out the required safety assessment for a cosmetic product before it goes on sale.

The Regulation is enforced across Great Britain by local authority Trading Standards services, under the Cosmetic Products Enforcement Regulations 2013 (as later amended by the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019).

Note on regional terms:

• UK = England, Scotland, Wales, and Northern Ireland
• GB (Great Britain) = England, Scotland, and Wales only

Rules on Animal Testing

Testing a finished cosmetic product, or any single ingredient used in one, on animals is illegal under UK cosmetics law.

There are also restrictions on which cosmetic ingredients can be supplied if their final formulation has, at any point, been animal-tested.

Because this is a highly technical area, businesses needing detailed guidance should consult a specialist or refer directly to the relevant sections of assimilated Regulation (EC) No 1223/2009.

Composition Requirements

There are strict rules governing which ingredients may or may not be used in cosmetic formulations, along with restrictions on quantities and required safety precautions. These details are extensive and are set out in the annexes to the Regulation rather than summarised here — businesses should seek specialist advice where needed.

Who is the “Responsible Person”?

Every cosmetic product placed on the UK market must have a designated Responsible Person based in the UK. This can be:

• The manufacturer based in the UK, or
• Someone else nominated in writing by the manufacturer to take on this role, or
• A distributor who places an already-marketed product under their own name or trademark, or who modifies it in a way that could affect compliance, or
• The importer (established in the UK) who brings in a product from outside the UK

Good Manufacturing Practice

Manufacturers must follow good manufacturing practice. Compliance is presumed where the manufacturing process follows the relevant British Standard (BSI-approved standards where designated).

Product Safety Assessment

Before a cosmetic product can be sold, the Responsible Person must ensure it is safe. This requires:

• A qualified safety assessment carried out by someone holding a relevant degree in pharmacy, toxicology, medicine, or a similar discipline (or equivalent recognised qualification/experience)
• A full cosmetic product safety report kept on file
• Access to a Product Information File (PIF), held at the Responsible Person’s registered address in the UK, which must be made readily available to enforcement authorities on request
• In a medical emergency, the same information must be shared promptly with authorities, and made available in English or another appropriate language upon request

What the Product Information File (PIF) Must Include

• The full qualitative and quantitative formula of the product (perfume/fragrance composites can instead be referenced by name/code and supplier details)
• Physico-chemical and microbiological specifications of both raw materials and the finished product, along with evidence of good manufacturing practice
• The manufacturing method used
• A signed safety assessment report from a qualified safety assessor, in line with Regulation (EC) No 1223/2009 — including specific criteria for products intended for children under 3 or for use in intimate hygiene
• Data showing the product complies with the Cosmetic Products (Safety) Regulations 1989, particularly regarding dangerous imitations (e.g. products resembling food)
• Any existing evidence of adverse effects on human health from using the product, made available to the public on request
• Justification for any marketing claims made about the product
• Any animal-testing data related to development and safety evaluation of the product or its ingredients

Submitting Information Before Sale

Before placing a cosmetic product on the UK market, the Responsible Person must submit the following details to the UK government via the Submit Cosmetic Product Notification (SCPN) service:

• The product category and its name(s), sufficient for clear identification
• The name and address of the Responsible Person
• Contact details of a named individual who can be reached in case of necessity (if the PIF isn’t easily accessible), where the product is imported into the UK

Marking and Labelling

Cosmetic products must display certain information directly on their packaging or labelling.

Name and Address

The name and address of the UK Responsible Person must appear on both the container (tube, bottle, jar, etc.) and outer packaging (box or carton). If the product was manufactured outside the UK, the country of origin must also be shown.

Where an EU responsible person is also named, their details must be replaced or supplemented with those of the UK Responsible Person.

Durability

If a cosmetic product has a shelf life of 30 months or less, it must display a best-before date on the packaging, shown as “Best used before the end of [date]” — either the day/month/year or an indication of where this date is printed elsewhere on the packaging. Any special storage conditions needed to keep this durability accurate must also be stated.

For products with a shelf life exceeding 30 months, instead of a best-before date, the packaging must show a “Period-After-Opening” (PAO) symbol — an open jar icon with a number and “M” (for months) indicating how long the product remains safe to use once opened.

Precautions

Any special precautions relevant to using the product safely (as outlined in the Regulation’s annexes) must be printed on the label — this includes any professional-use-only instructions, such as those for hairdressing products.

Batch Code

Every product must carry a batch number or manufacturing reference so it can be traced.

Function

The product’s purpose must be stated, unless this is already obvious from its packaging or design.

Nominal Quantity

The net weight or volume must be declared, with some exemptions — for example, free samples, single-use sachets, or packs containing less than 5ml/5g.

Ingredients Labelling

General Requirement

Every cosmetic product supplied in the UK must carry a full list of its ingredients, headed “Ingredients,” listed in descending order of weight as measured at the time each ingredient was added during manufacture. This applies to products sold in retail, mail order, online, multi-part kits, and even items supplied to hotels or given away as free professional/promotional samples.

Not required to be listed:

• Trace impurities carried over from raw materials
• Substances used only during manufacturing that don’t remain in the final product
• Materials used purely as solvents or carriers for fragrance/aromatic compounds

Fragrance ingredients can generally just be labelled as “perfume” or “aroma,” unless a specific fragrance component must be disclosed separately under Annex III of the Regulation.

Minor ingredients: Anything present at less than 1% concentration can be listed in any order after the ingredients above that threshold.

Colourants: These can be listed in any order after the other ingredients (using their designated colour index number), except in decorative products sold in a range of shades — where all shades used across the range may be listed together using “may contain” or the “+/–” symbol.

Naming Convention

Ingredients must be named using International Nomenclature of Cosmetic Ingredients (INCI) terminology. If no INCI name exists, one of these alternatives may be used instead:

• Chemical name
• European Pharmacopoeia name
• WHO’s International Non-proprietary Name (INN)
• EINECS (European Inventory of Existing Commercial Chemical Substances) reference
• IUPAC name
• CAS (Chemical Abstracts Service) number

A public database of INCI names is available via the Europa website.

Nanomaterials: Any ingredient present in nanomaterial form must have “(nano)” added after its name in the ingredients list.

Confidentiality

There is a formal process allowing manufacturers to request that certain ingredient names remain confidential.

Cross-Border Naming Conventions

For consistency, industry bodies have agreed naming conventions across markets. In the UK, the Cosmetic, Toiletry and Perfumery Association (CTPA) recommends that “aroma” be replaced with “perfume” and that ingredient names appear in capital letters. If exporting, sellers should check whether the destination country accepts these same conventions.

Presentation of Required Information

All mandatory information must be clearly visible, permanent, and easy to read — both in English and in any other language used elsewhere on the packaging.

There are separate presentation rules for the ingredients list versus all other required information.

Ingredients List Placement

The ingredients list must normally appear directly on the packaging. If the product is sold unpackaged, or if listing ingredients directly on the packaging isn’t practical, the list can instead appear on a nearby notice at the point of sale.

Where space is genuinely too limited to include the ingredients list on the product or its immediate packaging, it may instead be provided on an attached leaflet, tag, label, or card — indicated by a reference symbol (the “hand and book” symbol) directing the consumer to check there.

For small unpackaged items — such as soap bars, bath balls, or similar small products — practical exceptions apply for how ingredient information is displayed, and it can be provided via an attached label/tag rather than printed directly on the item.

Other Required Information (batch code, etc.)

All other mandatory details (batch code, function, name/address, etc.) must normally appear on both the outer packaging and the container itself. If this is genuinely impractical, this information can instead appear on a nearby notice, or on an attached label/tag/leaflet, as long as a clear reference is given pointing the consumer to it.

Making Claims About Cosmetic Products

Under assimilated Regulation (EU) No 655/2013, any claims made about a cosmetic product — on packaging, in advertising, or elsewhere — must be:

• Legal
• Truthful
• Honest
• Fair
• Clear and understandable to the average consumer

“Free-from” claims: These should not be used to highlight the absence of an ingredient that isn’t typically used in that type of product anyway (e.g. claiming a shampoo is “free from parabens” when parabens aren’t normally used in shampoos in the first place is misleading, unless there’s a genuine reason consumers would expect it).

For more detail on how claims are assessed, the European Commission has published a technical document on cosmetic claims that sets out common justification criteria.

Microbeads

It is illegal to manufacture or sell rinse-off personal care products (such as face washes or exfoliants) that contain plastic microbeads.

Product Recalls and Safety Concerns

If a Responsible Person becomes aware, or has reasonable grounds to believe, that a cosmetic product does not comply with the Regulation, they must act immediately — withdrawing or recalling the product as necessary — and must inform their local Trading Standards service, providing full details of the non-compliance and the corrective action taken.

Importers must also keep records of:

• Any substances present in nanomaterial form and their identification
• The formulation, in a way that allows for prompt and appropriate medical treatment if something goes wrong

Key Legislation

• Assimilated Regulation (EC) No 1223/2009 on cosmetic products
• Cosmetic Products Enforcement Regulations 2013
• Assimilated Regulation (EU) No 655/2013 – common criteria for justifying claims about cosmetic products
• Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019
• Toys and Cosmetic Products (Restriction of Chemical Substances) Regulations 2022

Following the UK’s departure from the EU in 2021, certain pieces of assimilated law continue to apply as they stood at that time, unless replaced by new UK legislation. This page may not reflect subsequent EU changes, which no longer automatically apply in the UK.

This information is intended for general guidance only. Only the courts can give an authoritative interpretation of the law. For legal certainty on your specific product, consult a qualified professional or your local Trading Standards service.

Source guidance: Chartered Trading Standards Institute – Business Companion: Cosmetic Products