Buying Guides
Cosmetic Labels for the EU Market: What to Print So Your Products Meet Regulation 1223/2009
What Article 19 of Regulation 1223/2009 requires on an EU cosmetic label, how the expiry date and the PAO symbol differ, and the 2026 fragrance-allergen change.
If you print only nine things, print these — on both the container and the outer packaging, in lettering that is indelible, easily legible and visible: (1) the name and address of the EU Responsible Person, (2) the country of origin for an imported product — “Made in China”, (3) the nominal content, e.g. 6 ml ℮, (4) either a best-before date or the period-after-opening symbol, (5) any particular precautions for use, (6) the batch number, (7) the product’s function, unless it is already obvious, (8) the full list of ingredients in EU INCI form, and (9) a scannable GS1 barcode. Items 1–8 are Article 19 of Regulation (EC) No 1223/2009. Item 9, again, is not in the Regulation at all — it is what EU retailers and marketplaces require. This article works through each one, with the durability decision and the expanded fragrance-allergen list that changed in 2026.
Who is named on an EU label — and why a Chinese factory address is not enough?
Every cosmetic sold in the EU must name a Responsible Person (RP) established inside the EU, with the address where the product’s Product Information File (PIF) can be accessed. A product made in China cannot be placed on the EU market under the factory’s name alone — your EU importer, or a professional RP company they appoint, takes that role.
Article 19(1)(a) requires the name or registered name and the address of the Responsible Person on the container and the packaging. If several addresses are shown, the one where the PIF is made available must be highlighted — in practice, underlined. The RP is the legal owner of compliance for that product in the EU: they hold the PIF including the Cosmetic Product Safety Report (CPSR), they made the CPNP notification before the product was placed on the market, and authorities and consumers reach them at that printed address.
For an imported product, the same part of the label block carries the country of origin: print “Made in China” clearly alongside the RP details. Do not let a design where the RP’s European address is large and the origin is missing or hidden imply the product was made in Europe — that is exactly the kind of misleading presentation EU market-surveillance authorities look for.
Two more items belong to this “identity” group:
Nominal content — the amount in the pack at the time of packaging, by weight or volume: “6 ml” or “4 g”, normally followed by the ℮ mark, which signals the fill complies with the EU average-quantity system. Exceptions exist for contents under 5 g or 5 ml, free samples and single-use items.
Function of the product — what it does (“lip gloss”, “coloured nail polish”), unless that is already clear from the name, pictures and description on the pack. On a small lip gloss tube it usually is; on a multi-use balm it usually is not.
FRONT — CONTAINER & CARTON
YOUR BRAND
Lip Gloss
Rose Shine · Shade 04
6 ml ℮
▭ 12M
Open jar — PAO
⌛
Hourglass — best before
(only if ≤ 30 months)
Leaflet reference
(text too long for pack)
Front carries name, function, shade and nominal content with ℮ mark.
BACK — CONTAINER & PACKAGING
Ingredients: Aqua, Glycerin, … Parfum, Limonene, Linalool, CI 77891, CI 16035. May contain: CI 77491.
Precautions: For external use only. (In the language of the country of sale.)
Responsible Person: [EU RP Name], [EU address where the PIF is held] Made in China · Batch: LG2607A
6 901234 567890
Illustrative EAN-13 layout — not a scannable code.
Expiry date or open-jar symbol — which one does your product need?
The EU does not ask for a manufacturing date. It asks a durability question with two branches: if the product’s minimum durability is 30 months or less, print the best-before date with the hourglass symbol; if it is more than 30 months, print the period after opening (PAO) with the open-jar symbol instead. A traceable batch number is required either way.
Which mark applies depends on your product’s proven minimum durability (from stability testing, as documented in the safety report):
30 months or less (e.g. 24 months): Print: hourglass symbol + best-before date. Your durability is 30 months or less, so the pack (container and packaging) shows the date of minimum durability — preceded by the hourglass symbol or the words “best used before the end of” in the language of the country of sale — as month/year or day/month/year, e.g. 06/2029. The PAO open-jar symbol is not the marking for this branch. Batch number still required.
More than 30 months (e.g. 36 months): Print: open-jar symbol + PAO. Your durability is over 30 months, so no best-before date is required. The pack (container and packaging) shows the period-after-opening symbol followed by the period from your stability data — e.g. 12M — on both the gloss tube and its carton. Batch number still required.
More than 30 months — single-use, aerosol, or never opened in use: Print: batch number; no PAO symbol. For single-use products, aerosols and similar presentations, the period-after-opening concept is not relevant, so the open-jar symbol is not used. Keep the reasoning in the Product Information File, and still print the batch number on container and packaging.
Marking — When it applies — How to print it
Date of minimum durability (best before) — Minimum durability ≤ 30 months — Precede the date with the hourglass symbol or the words “best used before the end of”, in the language of the country of sale. Give month + year, or day + month + year, in that order — e.g. 06/2029. Add storage conditions if the date only holds under them.
Period after opening (PAO) — Minimum durability > 30 months — The open-jar symbol followed by the period in months and/or years — 6M, 12M, 24M — on both container and packaging. The figure must come from your stability and microbiological data in the CPSR, not from a competitor’s pack.
No PAO needed — Where durability after opening is not relevant — Single-dose products, aerosols and similar presentations where the product is not opened in normal use do not carry the open-jar symbol. Record the reasoning in the product file — “everyone else prints 12M” is not a substitute either way.
Batch number — Always — The batch number of manufacture, or another reference identifying the product, on container and packaging; if the product is genuinely too small, on the packaging alone. This is the code that links the unit to its production run in a recall.
Manufacturing date — Not an EU legal requirement — Many EU buyers still ask for an open MFG date next to the batch code for warehouse rotation. If you print one, keep its format identical across markets — MFG: 07/2026 — and make sure it never replaces the legal best-before date or PAO above.
The two markings are alternatives in the Regulation’s logic: a short-life product is controlled by its calendar date, a long-life product by how long it stays safe once the consumer opens it. Printing a random “EXP” date copied from a US buyer’s spec, next to a PAO symbol, with neither supported by stability data, is worse than either one done properly — your safety assessor signs the CPSR against what the pack says.
How do you write the EU ingredient list — including the 2026 allergen change?
Head the list with the word “Ingredients”, use EU INCI names in descending order of weight at the time they are added, name fragrance allergens individually once they pass the legal thresholds — and since 31 July 2026, products newly placed on the EU market must do this for the expanded list of around 80 allergens, not the old list of about 26.
Order and heading: the list is preceded by “Ingredients” and ordered by descending weight when the ingredient is added to the product. Ingredients under 1% may follow in any order. The list may appear on the outer packaging alone if space is genuinely tight — but for a product sold without a carton, it must be reachable, e.g. on an attached leaflet signalled by the open-book symbol.
EU names: “Aqua” for water, “Parfum” (or “Aroma”) for fragrance compositions, and CI numbers for colourants — CI 77891, CI 77491 — which may be listed in any order after the other ingredients. Multi-shade ranges use “May contain” or “+/-”. A nanomaterial is followed by [nano], e.g. “Titanium Dioxide [nano]”.
Fragrance allergens: an allergen in Annex III must be named individually in the list when it exceeds 0.001% in a leave-on product (lip gloss, lipstick) or 0.01% in a rinse-off product. Commission Regulation (EU) 2023/1545 added 56 more allergens, taking the total to around 80 — including substances common in essential oils and botanical extracts, such as vanillin, menthol and camphor. Products that do not comply may no longer be placed on the EU market since 31 July 2026; stock already placed before that date may continue to be made available until 31 July 2028. If you are printing artwork now, print to the new list — and get the allergen breakdown from your fragrance supplier in writing, calculated on the finished product, not on the fragrance oil.
Warnings travel with ingredients: where an Annex III ingredient carries conditions — a warning wording, a maximum concentration, “contains X” statements — that wording goes on the label too, in the language of the country of sale. The INCI names themselves are not translated; everything around them is.
And the barcode?
Nothing in Regulation 1223/2009 mentions barcodes. In practice EU retail runs on EAN-13: license a GTIN-13 from GS1 (a Chinese brand typically registers through GS1 China — a 690–695 company prefix — which is valid worldwide and says where the company is registered, not where the product is made; that is what “Made in China” is for). One GTIN per shade and size, printed at a size and contrast scanners accept, on a flat area of the carton. If the same product already has a US GTIN-12, ask GS1 or your retailer how they want it represented for the EU listing instead of inventing a second number — duplicate or conflicting GTINs cause listing rejections in both markets.
Language, claims and pack symbols — what else does the EU check?
Three things catch exporters after the Article 19 list is complete: the label is in the wrong language for the country of sale, a claim on the front cannot be supported, and a familiar-looking symbol (Green Dot, recycling marks) is treated as if it were an EU-wide legal requirement when it is not — while the national rule that does apply gets missed.
Language: the RP name/address, nominal content, durability wording, precautions, batch reference and function must be understandable to consumers in the member state where the product is sold — in practice, in that state’s official language(s). One English-only artwork rarely covers the whole EU. Plan language clusters, multi-language cartons, or peel-off / booklet labels for smaller markets.
Claims: Regulation (EU) No 655/2013 sets common criteria — legal compliance, truthfulness, evidential support, honesty, fairness, and allowing the user to make an informed choice. “Dermatologist tested”, “hypoallergenic”, “24-hour moisture” each need evidence held in the PIF. A claim that a cosmetic treats a disease is not a labelling fix; it takes the product outside cosmetics law altogether.
Symbols, honestly sorted: the hourglass, open jar, open book (refer to enclosed information) and ℮ mark come from the Regulation’s Annex VII and the quantity rules. The Green Dot is a trademark showing the producer joined a packaging-recovery scheme — it is not an EU labelling requirement and does not mean the pack is recyclable. Sorting and recycling information is mandatory in some member states under national packaging rules — France’s Triman + Info-tri and Italy’s environmental labelling are the well-known examples — so confirm the destination country’s packaging marks with your importer, pack by pack.
Small products: lip gloss tubes and lipstick cases are exactly the products Article 19 anticipates. Where the container is too small, the batch number may sit on the outer packaging only, and longer information can move to an enclosed leaflet, tag or tape — signposted on the pack with the open-book symbol. “Too small to read” is never solved by shrinking the ingredient list until it is illegible; legibility is itself a requirement.
Pre-print checklist — European Union
Container AND outer packaging both carry the full Article 19 information, legible and indelible
Responsible Person: EU name + address, PIF address highlighted; CPNP notification done, CPSR and PIF in place
“Made in China” origin marking present for the imported product, next to the RP block
Nominal content with ℮ mark — 6 ml ℮ — correct at time of packaging
Durability decided and evidenced: ≤ 30 months → hourglass + best-before date; > 30 months → open-jar PAO (6M / 12M / 24M)
Batch number identical on container and packaging; MFG date added only if the buyer’s specification asks for it
Ingredients: “Ingredients” heading, EU INCI names, descending order, CI numbers, [nano] where it applies, “May contain” for shade ranges
Fragrance allergens checked against the expanded (~80) list, thresholds 0.001% leave-on / 0.01% rinse-off, supplier declaration on file
Precautions, function and durability wording in the language(s) of every country of sale
GS1 EAN-13 barcode, one GTIN per shade/size, scan-tested; destination country’s recycling marks (e.g. France Triman) confirmed with the importer
FAQ — EU cosmetic labels
Do I need both an expiry date and the open-jar PAO symbol?
Normally one or the other, decided by shelf life. At 30 months minimum durability or less, the pack shows the date of minimum durability (hourglass symbol or “best used before the end of” plus the date). Above 30 months, that date is not required and the pack instead shows the period after opening — the open-jar symbol with, for example, 12M. Where PAO is not relevant (single-use, aerosols), neither branch adds an open-jar symbol, but the batch number is still required.
Is a manufacturing date required on EU cosmetics?
No. Regulation 1223/2009 requires a batch number for traceability and a durability indication (best-before date or PAO) — not a printed production date. Many buyers ask for an open “MFG” date as a commercial specification for stock rotation. Print it if your buyer asks, in a clear format, but never in place of the legal durability marking.
Can a factory in China be the Responsible Person?
No. The Responsible Person must be established within the EU. For imported products that is normally your EU importer, or a specialist RP company the importer appoints. Their name and the address where the Product Information File is held go on the label, and they carry the legal responsibility for the product in the EU.
Does EU law require an EAN barcode?
No — the Cosmetics Regulation does not mention barcodes. EAN-13 from a GS1-licensed GTIN is a retail and marketplace requirement across Europe, and in practice no supermarket or beauty chain lists a product without one. Budget for one GTIN per shade and per size, the same discipline as for US UPCs.
What changed with fragrance allergens in 2026?
Regulation (EU) 2023/1545 added 56 fragrance allergens to the individually-labelled list, bringing the total to around 80, at the same thresholds: above 0.001% in leave-on and 0.01% in rinse-off products. Since 31 July 2026, non-compliant products may no longer be placed on the EU market; products placed before that date may be sold through until 31 July 2028. New artwork should always use the expanded list, and the CPSR and CPNP entry must match it.
Can the label be in English only?
For most member states, no. The mandatory consumer information — precautions, function, durability wording and similar — must be in the official language(s) of the country where the product is sold, as that country’s law determines. INCI ingredient names are the exception: they are used as-is across the EU. Multi-language packaging or booklet labels are the normal solution for small products sold in several countries.
Next step. Send us your current label draft, the full ingredient list with the fragrance-allergen breakdown, your stability result (which fixes the best-before / PAO branch) and the EU countries you plan to sell into. We will mark up what has to change for the EU before you print.
