What a Cosmetic Label Should Include – A Guide for Brand Owners

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Creating your own cosmetic brand is not only about product development, but also about significant legal responsibility. The cosmetic product label is one of the key elements — errors in labeling can lead to penalties, product recalls, or brand reputation damage. Below is what must be included, the applicable requirements, and the regulations that govern them.

Legal Basis — EU and Poland

  • Regulation (EC) No. 1223/2009 of the European Parliament and of the Council on cosmetic products – the EU Cosmetics Regulation.

  • Polish Act of October 4, 2018 on Cosmetic Products, which implements EU legislation at the national level.

These regulations define requirements regarding labeling, consumer information, health protection, and product liability. Regulation (EC) 1223/2009 also includes Annexes regulating ingredients, preservatives, colorants, UV filters, etc.

What Must Be Included on a Cosmetic Product Label (EU + Poland)

Element Requirements / Notes
Product name + function You must clearly indicate what the product is and what it is used for (e.g., “shampoo,” “day cream,” “face scrub”), unless the function is obvious from the presentation.
Responsible Person Name and address of the person/company placing the product on the EU market. This may be the manufacturer, importer, or distributor acting as the Responsible Person (RP).
Nominal content (weight/volume) The amount of product in the package (e.g., ml, g). Some exemptions apply to very small packaging (e.g., samples under 5 ml/g).
Date of minimum durability or PAO If shelf life unopened is less than 30 months → “Best used before the end of…”.
If more than 30 months → use the PAO (Period After Opening) symbol, indicating how long it can be safely used after opening.
Warnings / Instructions for use Required when the product needs caution (e.g., avoid eye contact) or when usage instructions are necessary.
Batch number Required for product traceability, safety, and potential recalls.
Full ingredient list (INCI) Must list all ingredients in descending order by weight. International INCI names must be used. Colorants, preservatives, and UV filters must comply with the Regulation Annexes.
Language The label must be in the official language of the country where the product is sold — in Poland: Polish is mandatory.
Country of origin Required if the product is imported from outside the EU.

Additional Label Requirements

  • Labels must be durable, legible, and visible — resistant to wear, water, and light.

  • Information must not mislead the consumer. Claims (e.g., “natural,” “organic,” “paraben-free”) must be truthful and verifiable.

  • Fragrance allergens — Regulation (EU) 2023/1545 updates allergen labeling requirements. If fragrance allergens exceed specific thresholds, they must be listed on the label.

Product Information File (PIF)

Separate from the label, every cosmetic must have a PIF (Product Information File).
This includes:

  • Safety assessment

  • Ingredient and formulation documentation

  • Evidence of product claims

  • Proof of compliance with Annexes of Regulation (EC) 1223/2009

The PIF must be available to market surveillance authorities.

Common Mistakes to Avoid

  • Missing Polish language when selling in Poland → product may be flagged by sanitary authorities.

  • Incorrect durability indication (PAO vs. “best before end”).

  • INCI list incomplete or using non-approved names.

  • Marketing claims that cannot be substantiated (e.g., “100% natural,” “chemical-free”).

  • Labels printed too small, unclear, or easily damaged.