Cosmetic Bottle and Box Labels: What Goes on Each Under EU Law

What do cosmetic bottle and box labels each have to carry?

As a rule, Article 19 places the Responsible Person's details, the nominal content, the durability information and the batch number on both the container and the packaging.

The container is the bottle, jar, tube or pan that holds the product, and the packaging is the box, carton or sleeve around it. The table lists each item by location and its Article 19 point, as worded in the Regulation as adopted.

Item	On the bottle (container)	On the box (packaging)	Article 19 point
Name or registered name and address of the Responsible Person	Yes	Yes	Article 19(1)(a)
Nominal content by weight or volume	Yes, as a rule	Yes, as a rule	Article 19(1)(b)
Date of minimum durability or, where the rule allows, the period after opening	Yes	Yes	Article 19(1)(c)
Batch number of manufacture or a reference identifying the product	Yes, as a rule	Yes	Article 19(1)(e)
List of ingredients	May be left off when the box carries it	Yes, and may be the only place	Article 19(1)(g)
Precautions or ingredients that cannot practically be labelled	An enclosed or attached leaflet, label, tape, tag or card, referred to on the pack		Article 19(2)

Which items may appear on the box alone?

Article 19(1)(g) lets the ingredients list sit on the packaging alone, so the box can carry it and the bottle can leave it off.

As a rule, the other items in the table still need a place on the bottle, jar or pan, however much text the box carries. A box that carries every item does not rescue a bare container, apart from the ingredients list, which the box may carry alone. Article 19(1) sets exceptions for small products, covered in the next section. The full list of Article 19 items, with every point, is in the guide to EU cosmetics labelling requirements.

Where the precautions or ingredients cannot practically be labelled, Article 19(2) allows an enclosed leaflet, label, tape, tag or card, referred to on the pack. That route covers the precautions and the ingredients only, and it applies only where labelling them in the usual way is not practical. It does not move the Responsible Person's address, the nominal content, the durability information or the batch number off the container.

What if there is no box, or the container is a small pan?

With no box, the container is the only pack, so as a rule it carries every item that Article 19 places on both the container and the packaging.

A jar placed on the market without a carton therefore carries the Responsible Person's details, the nominal content, the durability information and the batch number itself. Its ingredients list goes on the jar as well, or on an enclosed leaflet or card where Article 19(2) applies and printing is impractical.

Small containers raise the same question in a harder form, because a pan or a sample jar has very little room for text. A pan or palette is the container and its sleeve is the packaging, so the sleeve may carry the ingredients alone under Article 19(1)(g). The other items belong on the pan as a rule, but Article 19(1) has exceptions for small products. Where a product is too small for practical reasons, point (e) lets the batch number appear on the packaging only, and point (b) sets its own exceptions for the nominal content, including free samples and single-application packs. Read each point in full before relying on the general rule.

Whose name and address goes on both, and what changes when the monthly plan ends?

With Eldris as the EU Responsible Person, the label carries EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia, while the monthly plan runs.

Article 19(1)(a) asks for the name or registered name and the address of the Responsible Person on both the container and the packaging. A business established in the EU can hold the role itself, and its own name and address then go on the label. The Tallinn address is the EU label address only, and this post gives no address for a label for Great Britain.

Cancelling the plan takes effect at the end of the billing period, and Eldris's details must then come off labels and listings within 30 days. A brand should therefore plan any reprint for a new Responsible Person before it cancels, so that no stock still carries a lapsed name. Great Britain needs a separate appointment of a Responsible Person established in the UK, as the GOV.UK guidance for that market explains.

What does the Article 19 label review in the fee cover?

The per-formula fee on the pricing page includes the signed CPSR (Part A and Part B), the PIF, the Article 19 label review and the INCI ingredient list for one formula.

The review checks the label against Article 19, the rules that decide which text goes on the bottle and which on the box. The fee stays the same whatever the number of ingredients. The documents arrive in the Eldris portal, and the CPSR and PIF service page describes the service for each formula. The bottle-versus-box question on the FAQ page gives the short answer.

Laboratory tests are not in the fee, and Eldris does not run them, so any test report comes from a laboratory that sets the price. The Responsible Person is a separate service, with a per-market fee and a monthly plan, both shown on the same pricing page. Eldris files the EU notification only when it is your EU Responsible Person and you order the filing, and it is then a separate line in your quote total.

Frequently asked questions

Can a leaflet replace the Responsible Person's address on the bottle?

No. Article 19(2) allows an enclosed leaflet, label, tape, tag or card only where the precautions or the ingredients cannot practically be labelled. The Responsible Person's name and address stays on both the container and the packaging under Article 19(1)(a). A leaflet is a fallback for printing, not a second home for that information.

Does the period after opening replace the date of minimum durability?

Article 19(1)(c) asks for the date of minimum durability or, where that rule allows, the period after opening. Whichever applies appears on both the container and the packaging. The rule decides which of the two a product shows, not whether the bottle carries it.

Is the batch number needed on the bottle if the box has it?

As a rule, yes. Article 19(1)(e) puts the batch number of manufacture or a reference identifying the product on the container and on the packaging. Where the product is too small for practical reasons, the batch number may appear on the packaging only.

Does the label review cost extra?

The per-formula fee on the pricing page includes the signed CPSR (Part A and Part B), the PIF, the Article 19 label review and the INCI ingredient list for one formula. Laboratory tests and the Responsible Person are not included, and the EU notification is a separate line.

Can the sleeve of an eyeshadow palette carry the ingredients?

Yes. Article 19(1)(g) allows the ingredients list on the packaging alone, so the sleeve can carry it. If printing the list is impractical, Article 19(2) allows an enclosed leaflet, label, tape, tag or card, referred to on the pack.

What happens to the label if the Responsible Person plan is cancelled?

The appointment ends, and Eldris's details must come off labels and listings within 30 days. The container and the packaging then need the name and address of the next Responsible Person under Article 19(1)(a). Planning the reprint before cancelling avoids stock with a lapsed name.