Cosmetic Batch Number: Where It Comes From and Where It Must Appear

Who assigns a cosmetic batch number?

A cosmetic batch number comes from the production run, so the manufacturer's batch record is its normal source when a contract manufacturer makes the product.

The brand then takes the number for each run from that manufacturer and prints it on the container and the packaging. A brand that makes the product itself assigns the number when each run is made and records it against the formula used for that run. Whoever assigns it, the same number should appear in the production record and on every pack from that run.

The number's job is to tie a unit on the shelf back to the run that produced it. Article 19(1)(e) names the batch number of manufacture or the reference for identifying the cosmetic product, and the point itself sets no format. The Responsible Person has a stake too, because Article 11 counts the period for keeping the PIF, ten years, from the last batch of the product placed on the market.

Must a perfume's batch number appear on the bottle as well as the box?

As a rule, yes: Article 19(1)(e) puts the batch number or reference on both the container and the packaging of a cosmetic.

A perfume placed on the market as a cosmetic carries the number on the bottle and on the box, as a lipstick does on its tube and carton. As a rule, a number on the box alone does not meet the point. The exception is a product too small for practical reasons, which may carry the batch number on the packaging only. The batch-number question on the FAQ page gives the short answer.

The same rule covers a jar and its box or a palette and its sleeve, wherever a product has more than one surface. The number on each surface should identify the same run, so that the bottle and the box point to one production record. Read point (e) as adopted in full before relying on the small-product exception for a particular container.

What does a brand without batch numbers do?

Point (e) offers a second route: a reference for identifying the cosmetic product, which may be used in place of a batch number.

A brand with no manufacturer batch number can therefore define its own batching, meaning a code that it assigns to each production run. Alternatively it can define a reference that identifies the product, and as a rule the same code then goes on the container and the packaging of every unit.

One way to build a code is a product code plus the date of the run, with a record that links it to the formula. The point itself sets no format, so the brand chooses a scheme it can apply consistently from the first run onward. What matters is that the code identifies the run or the product and appears identically on every surface that carries it, including the box. Keep that record with the other product documents, because the Responsible Person keeps the PIF for ten years after the last batch is placed on the market.

How does the batch number relate to the date of minimum durability?

They are separate items in Article 19(1): the durability date or period after opening sits in point (c), and the batch number in point (e).

As a rule, each appears on both the container and the packaging of the product, as the guide to bottle and box labels shows item by item. Meeting one point does not meet the other, so a product needs both, whatever form its durability information takes. Both are among the items the Article 19 label review in the per-formula fee checks, with the Responsible Person's name and address and the nominal content.

Where the rule allows the period after opening in place of the date, that choice concerns point (c) only, not point (e). A product that shows a period after opening therefore still carries its batch number or reference. The period tells the user how long the product is safe once opened, and the batch number tells anyone else which run it came from.

How do batch numbers connect to the PIF and the label review?

The Responsible Person keeps the PIF under Article 11, and the period for keeping it runs from the last batch placed on the market.

Among the PIF's contents are the CPSR, the manufacturing method and a GMP statement. Batch identity therefore matters to the Responsible Person, and a clear numbering scheme lets anyone follow a unit from the label back to the manufacturing method held in the PIF.

The CPSR and PIF service includes the Article 19 label review, alongside the signed CPSR (Part A and Part B), the PIF and the INCI ingredient list for one formula. The per-formula fee on the pricing page covers all of it, whatever the number of ingredients, and the review checks the label against Article 19, which includes point (e). Laboratory tests and the Responsible Person are not included. The numbering itself stays with the brand or its manufacturer, and the rules for Great Britain are set out in the GOV.UK guidance.

Frequently asked questions

Can a reference replace the batch number?

Yes. Article 19(1)(e) accepts the batch number of manufacture or a reference identifying the product. A brand without batches can use its own product reference, printed identically on the container and the packaging. It should also keep a record that ties each reference to the formula and to the manufacturer.

I have no batch number yet. What should I print?

Define one. Article 19(1)(e) accepts a batch number of manufacture or a reference identifying the product. A code for each production run, or a product reference, therefore fits the wording of the point. Print the same code on the container and on the packaging, and record what it stands for.

If my product shows a period after opening, do I still need a batch number?

Yes. The period after opening belongs to Article 19(1)(c), and the batch number or reference belongs to point (e). Each point stands on its own, so one cannot stand in for the other. As a rule, both appear on the container and the packaging, whichever form of durability information the product shows.

Do perfumes, body mists and solid perfumes need a batch number?

Fragrance products such as eau de parfum, EDT, body mist and solid perfume are a cosmetic type that Eldris assesses. Article 19(1)(e) applies to them as to any cosmetic. As a rule, the batch number or reference therefore appears on both the bottle and the box, as for a lipstick.

Does the label review check the batch number?

The Article 19 label review in the per-formula fee checks the label against Article 19, and point (e) is part of Article 19. The review is one of the items in the fee for one formula, with the CPSR, the PIF and the INCI ingredient list.

Who decides the format of the batch number?

The brand and its manufacturer do. Article 19(1)(e) names the batch number of manufacture or a reference identifying the product and sets no format. The same code should appear on every surface that carries it, so that the bottle and the box match. Different codes on different surfaces would break the link back to one run.

What if every unit comes from a single production run?

A single run is still a batch of manufacture, so, as a rule, its number goes on both surfaces. A brand may instead use a reference identifying the product. Article 19(1)(e) accepts that in place of a batch number, and the brand should record which formula it belongs to.