Key takeaways
- Mandatory elements differ by market but the core set is consistent.
- The batch code and PAO are functional, not decorative.
- Every claim on the front panel needs evidence in the file.
Label approval is a one-way door: once the artwork is printed, a missing element costs a reprint and possibly a market withdrawal. The checklist below is the core set that covers most markets, and it should be completed before the final proof is signed.
1. Product name and function
The name and the function must be clear enough that a consumer knows what the product is. A name that implies a drug function, such as “cure” or “treat”, crosses the cosmetic boundary. The function wording should match the intended use in the CPSR.
2. Nominal content
The net weight or volume must be stated in the units the market requires, with the fill tolerance accounted for. A product that declares 30 ml and fills 29.4 ml fails a legal metrology check even if the average is correct.
3. Ingredient list
The INCI list in descending order down to 1 percent, then in any order, with colourants at the end. Water as aqua, fragrance as parfum plus the declarable allergens above the threshold. The list must match the formula exactly.
4. Responsible person
The name and address of the responsible person or the manufacturer, depending on the market. In the EU the responsible person’s address is required; in the US the manufacturer’s or distributor’s. A missing address is a common finding.
5. Country of origin
Required in some markets and voluntary in others, but a made-in claim must be accurate. A product assembled in one country from materials from three others has a specific origin under customs rules, and the label claim should match that rather than the assembly location.
6. Batch code
A batch code that allows traceability to the production record. The code must be legible and must not be printed over a dark background without contrast. A batch code that cannot be read is not a batch code.
7. PAO or durability date
Products with a shelf life above 30 months use the period-after-opening symbol with the number of months. Products below 30 months use a best-before date. The two cannot be used together.
8. Warnings and precautions
Required warnings depend on the formula and the market: sun exposure, eye contact, children, restricted ingredients. The warnings must match the CPSR. A generic warning list copied from another product is a compliance risk.
9. Directions for use
Directions must reflect the intended use that the safety assessment covered. A product assessed for external use cannot be labelled with an instruction that implies another use.
10. Claims and substantiation
Every claim on the label needs evidence in the file: hydration, wrinkle reduction, non-comedogenic, dermatologically tested, hypoallergenic. A claim without evidence is a claim that can be challenged in any market.
11. Language and legibility
The label must be in the language or languages the market requires, at a legible size, with sufficient contrast. A label that satisfies the content requirements but is illegible at 20 cm is non-compliant on the legibility requirement.
12. Symbols
The e-mark, the recycling mark, the flammability symbol, the green dot and the period-after-opening jar all have defined meanings and defined rules. A symbol used incorrectly is worse than a symbol omitted, because it is a specific false statement.
13. Barcode
The barcode must be scannable at the intended size, with the correct quiet zone and contrast. A barcode printed on a metallic or textured surface often fails at the point of sale, and the failure is discovered by the retailer.
14. Multi-pack and set rules
A set or a gift box needs the information for each unit or a statement that the information is on the individual packs. The rule differs by market, and a set assembled for gifting is exactly where it is tested.
15. Digital extension
A QR code can carry the full INCI list, the directions and the safety information. It does not replace the mandatory on-pack elements where those are required. A QR code that links to a dead page is a compliance failure with a modern surface.
16. Sign-off
Two signatures: one from the regulatory owner and one from the brand owner. A label approved by one person alone is a label that reflects one person’s understanding of one market.
17. Where it fits
Labelling runs across the gift set range; the naming detail continues in the INCI entry.
Reference: Label review checklists and artwork approval records, 2025
