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How to Label Small Cosmetic Products or Samples – EU, UK & Poland | Annel

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, with practical solutions to stay compliant and consumer-friendly.

Nominal Content (Weight / Volume)

  • No need to state nominal content if the product contains less than 5g or 5ml.
  • This exemption also applies to free samples and single-use packs.
  • 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)

  • Products with a shelf life under 30 months: show the “best before end of” date (EXP).
  • Products lasting over 30 months: show the PAO symbol (open jar with 6M, 12M, 24M).
  • Exemptions: aerosols, perfumes, highly stable single-use packs.

Batch Number

The batch or lot number is mandatory for traceability. If the container is too small, the batch code may appear on the outer packaging only. This is acceptable as long as it remains easily accessible to the end user.

Ingredients (INCI) List

  • The full INCI list may be provided on a leaflet, tag, peel-off label or carton.
  • If moved off the primary pack, the “hand & book” symbol must be used.
  • For very small items (mini soaps, bath bombs), INCI may appear at the point of sale.
  • Nanomaterials must always be marked with “(nano)”.

Other Mandatory Information

  • Responsible Person: must be established in the EU or UK.
  • Country of origin: required for imported goods.
  • Warnings and precautions: required where applicable (hair dye allergy alerts, etc.).
  • Function of the cosmetic: unless clearly inferred by the product type.
  • Language: must match the country where the product is sold (English for UK).

Specific Polish Requirements 🇵🇱

  • All mandatory information must be provided in Polish.
  • High readability is required—authorities may reject tiny or low-contrast print.
  • QR codes may supplement but never replace mandatory Polish text.
  • Importers automatically become the Responsible Person.
  • Sanctions include fines up to 100,000 PLN and product withdrawal.

Practical Solutions for Small Formats

  • Multi-layer or peel-off labels: ideal for sachets and minis.
  • Leaflets and swing tags: useful for sets, samples, and luxury minis.
  • Symbols and pictograms: save space and improve clarity.
  • QR codes: useful for additional content but cannot replace mandatory text.

Labelling Must Not Mislead

The overriding legal principle across both EU and UK law is that no label may mislead. This includes:

  • False or ambiguous claims
  • Attributing properties the product does not have
  • Incorrect or unclear presentation
  • Wrong language for the market

References

• Regulation (EC) No 1223/2009
• UK Cosmetic Products Enforcement Regulations