Labelling and the ingredient list
Artwork is the last thing to be decided and the thing an inspector, a retailer or a customer reads before anything else. It is also the most expensive thing to get wrong twice, because the second time you are paying a printer.
What the ingredient list has to do
The ingredient list is required by Art. 19(1)(g), Reg. (EC) 1223/2009. Three rules do most of the work:
- ingredients are listed in descending order of weight at the time they are added;
- ingredients at concentrations below 1 % may be listed in any order after those above 1 %;
- colorants may be listed in any order after the other cosmetic ingredients — with one exception the wording is easy to miss: the Regulation says "colorants other than colorants intended to colour the hair", so a hair colorant does not get that freedom.
That second rule is the one people misuse. Below 1 % the order is free — but the boundary itself is not, and an ingredient sitting just above 1 % in the batch sheet and below it on the pack is a real error, not a rounding convenience.
Then the names. An ingredient is listed by the common ingredient name set out in the glossary provided for in Art. 33, Reg. (EC) 1223/2009 — not by its marketing name, its botanical name in your own language, or the supplier's trade name. Perfume and aromatic compositions and their raw materials are given as "parfum" or "aroma" (Art. 19(1)(g)), and the allergen components in them are named separately once they cross the disclosure thresholds set in Annex III.
Check my product — free
Paste the product's public listing URL. We check which of the eight obligations are visibly met — free, while you wait — a screen of the public words, not a safety assessment.
No public page, or the list is only on the pack? Paste it instead
What we build, and where it stops
We generate the ingredient list from the formula rather than from a previous label. The composition is flattened to substance level through every raw material and compound, each name is resolved against the EU glossary, and the list is ordered and assembled from the result: descending, the 1 % boundary respected, colorants placed after the other ingredients by their colour index except colorants intended to colour the hair, the perfume composition collapsed, nano forms marked.
Where a name cannot be resolved, the generator stops and says which one. It does not guess a plausible INCI name, and it does not silently drop the ingredient. A fabricated name on a label is worse than a missing one, because it looks finished.
The same rule applies to allergens. Allergen names come only from registry entries that a person has transcribed from the instrument and dated. Nothing is asserted from memory, which means the generator will tell you it cannot complete the allergen line rather than produce one that looks complete.
It is the standard the rest of the practice runs on. A name we cannot resolve is reported, not invented, and a label is no different.
Artwork review
Send the artwork and we report, item by item, what appears on the container and on the outer packaging, what does not, and where the two disagree with each other or with the file: the responsible person's name and address (Art. 19(1)(a), Reg. (EC) 1223/2009), the ingredient list, the nominal content, the batch reference, the period-after-opening or durability mark, the warnings from the safety report, the country of origin where it applies.
We report presence, absence and mismatch. We do not write "compliant" on a piece of artwork, because a label is only ever compliant for a product, a market and a date — and the date moves.
The dates that are moving now
Fragrance allergen labelling changed under Reg. (EU) 2023/1545. Products that do not meet the new labelling could be placed on the Union market until 31 July 2026 — that date has passed — and may be made available on the Union market until 31 July 2028. So a jar already in a shop is one situation; a new batch is another, and the distinction between placing on the market and making available is doing all the work in that sentence.
Widely circulated summaries disagree about how many fragrance allergens the list now contains: CIRS states 81 and COSlaw states 82. We are not going to print a third number. The disagreement is the publishable fact; we count from the consolidated annex for your formula and cite the entries we counted.
Reg. (EU) 2026/909 of 27 April 2026 amends Annexes II, III, V and VI. Products not meeting it may not be placed on the Union market from 1 January 2027. The date for making available is not a single figure: 1 July 2028 for triphenyl phosphate (Annex II), for Annex III entries 381 and 382 and for DHHB (Annex VI entry 28); 1 August 2028 for citral (Annex III entry 70) alone. One blanket date for that instrument would be wrong in both directions. Note also the corrigendum of 8 May 2026, which changes an annex reference number from 1752 to 1767 — a file citing 1752 is citing the uncorrected text. A corrigendum of 5 May 2026 renumbers the new Annex III entries: the text as first printed numbers them 379–384, the corrected text 381–386.
Check what your listing shows
Paste the URL of a product you already sell. Without an email you see the listing screen: what the page can answer, marked visible on the listing or not visible on the listing, and a note for the work that lives in the file — plus how many ingredient names resolved, and any Annex II lines the screen matched. That part is free and asks for nothing.
Give an email and the report adds the claims read — each sentence with the criterion it touches — and arrives as a mail you can keep. We email you the full report. We may write to you once about registering the product. No newsletter, no list, and we delete the report and your address when you ask. What the check does, in full → · Privacy →
A listing is not a label, so what comes back is a screen of the public words rather than a safety assessment.
Check my product — free
Paste the product's public listing URL. We check which of the eight obligations are visibly met — free, while you wait — a screen of the public words, not a safety assessment.
No public page, or the list is only on the pack? Paste it instead
The ingredient list and the artwork review are part of registration — see the prices →. Once a product is already registered, a later change to the label or the packaging, with the recipe and the exposure unchanged, is €280 per change.
An artwork review can be bought on its own. Get a fixed quote →: products, variants, markets and country of origin. You get a fixed quote in writing. The lines we charge, and what moves them →
Questions people ask
Do ingredients under 1% have to be in order?
No. Ingredients present at less than 1 % may be listed in any order, after the ones above 1 % (Art. 19(1)(g), Reg. (EC) 1223/2009). What still has to be right is which side of the boundary each ingredient falls on, and that comes from the formula, not from the previous label.
My formula is botanical and some ingredients have no INCI name — can it be labelled at all?
Usually yes, and this is ordinary work rather than an exotic case. Traditional and regional materials often exist in the glossary under a name the maker has never used, and the resolution is a matching problem. Where no glossary name exists for a material as supplied, we will tell you that plainly — with the alternatives, which normally means a different specification of the same material rather than abandoning it. What we will not do is invent a name that looks like an INCI name.
Does the responsible person's address have to be on the label?
Yes. The container and packaging must bear "the name or registered name and the address of the responsible person" (Art. 19(1)(a), Reg. (EC) 1223/2009). Whoever is designated is the address that appears — which is why this is a question about who your responsible person is, not about label design. Whose address goes on the label, in full →
Will my home address have to go on the label?
Only for as long as you are the designated responsible person. Designate someone established in the Union and their registered address is the one printed. We can be appointed as your EU Responsible Person, by written mandate. Get a fixed quote →
Do I have to relabel stock I have already made?
It depends on which side of a transitional date each batch falls, and the two dates in each instrument mean different things. For the fragrance allergen change under Reg. (EU) 2023/1545, the date for placing on the market has passed and the date for making available is 31 July 2028. Tell us what you have in the warehouse and when it was placed on the market and we will work it through with you against the text.
Can I just send you the label I already use?
Send it, but send the formula too. A label checked against a previous label reproduces whatever was wrong in that earlier one. The ingredient list has to be generated from the composition to mean anything.
Start with the free check — see what your listing is missing, while you wait.