How to Label Small Cosmetic Products or Samples in the EU, UK & Poland
Labelling cosmetics is never simple – and it becomes even more challenging when dealing with small packaging such as samples, sachets, miniatures or travel sizes. Both the European Union (including Poland) and the United Kingdom follow Regulation (EC) No 1223/2009, but there are important local differences worth noting.
This guide explains the most important rules for small cosmetic product labelling in the EU, UK and Poland, together with practical solutions to stay compliant and consumer-friendly.
Nominal Content (Weight / Volume)
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No need to state nominal content if the product contains less than 5g or 5ml.
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This exemption also applies to free samples and single-use packs.
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In all other cases, the weight or volume must be indicated (e.g. 50 ml, 200 g).
Date of Minimum Durability & Period After Opening (PAO)
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Products with a shelf life under 30 months: show the “best before end of” date (EXP).
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Products lasting over 30 months: show the PAO symbol (open jar with 6M, 12M, etc.).
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Exemptions: single-use packs, highly stable products such as aerosols and perfumes
Batch Number
The batch or lot number is mandatory for traceability. If the container is too small, the batch code can appear only on the outer packaging.
This is acceptable as long as it remains easily accessible to the end user
Ingredients (INCI) List
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The full list of ingredients may be provided on a leaflet, tag, peel-off label or carton.
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When information is moved off the primary pack, the “hand & book” symbol (📖✋) must be used.
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For very small items (e.g. mini soaps, bath bombs), the INCI list can be displayed at the point of sale if there is no space on the packaging.
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Nanomaterials must always be marked with “(nano)”
Other Mandatory Information
Even for very small products, the following must always be present (on the product or its packaging):
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Responsible Person: Name and address (abbreviated if identifiable). Must be established in the EU or UK, depending on where the product is sold.
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Country of origin: Required for imported goods.
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Warnings and precautions: Must be stated if applicable (e.g., hair dye allergy alerts).
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Function of the cosmetic: Unless clearly inferred by the product type (e.g., lipstick).
The information must be:
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Accurate
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Legible
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In the language of the country where the product is sold (English for UK).
Specific Polish Requirements 🇵🇱
For cosmetic products placed on the Polish market:
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Language: All mandatory information must be provided in Polish, except the INCI list.
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Readability: Labels must be legible and comprehensible; authorities may reject small print or poor contrast.
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QR codes: allowed as supplementary information but cannot replace legally required text in Polish.
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Importer responsibility: Importers automatically become the Responsible Person and must ensure labelling compliance before marketing.
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Sanctions: Non-compliance can lead to fines of up to 100,000 PLN and product withdrawal by the State Sanitary Inspection (Państwowa Inspekcja Sanitarna).
Practical Solutions for Small Formats 💡
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Multi-layer or peel-off labels: ideal for sachets and minis.
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Leaflets and swing tags: useful for gift sets, samples, and luxury minis.
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Symbols & pictograms: save space and improve clarity.
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QR codes: excellent for additional content (marketing, sustainability) but never a substitute for mandatory details
Labelling Must Not Mislead
The overriding legal principle across both EU and UK law is that no label may mislead. This includes:
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False or ambiguous claims
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Attributing properties the product does not have
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Unreadable or misleading presentation of text
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Presented in the official language(s) of the market (Polish in Poland, English in the UK, local languages in other EU states).
Even on the smallest sachet or tester, your label carries the same legal weight as full-size products.