Responsibility sits with a person, not with a printer
The starting point that most first-time brand owners miss: cosmetic products placed on the Great Britain market have a designated responsible person, and that role carries specific duties. It is not a formality and it does not transfer automatically to a contract manufacturer because they made the product.
Establish in writing, before production, who the responsible person is for each product in the range, who holds the product information file, who arranges the safety assessment, and who handles notification. A manufacturer telling you they take care of compliance is not an answer to any of those questions. It is a statement that needs converting into named duties in a contract.
Compliance is a set of named responsibilities. If nobody can tell you who holds each one, nobody holds it.
What the label has to carry
Label requirements consume physical space, which is why they have to be settled before artwork rather than after. In outline, and without substituting for the primary sources:
- The name and address of the responsible person.
- The nominal quantity of the contents.
- Durability information, in the required form for the product.
- Precautions for use, including any particular conditions of use.
- A batch number or other identification of the batch.
- The function of the product, unless it is clear from presentation.
- The ingredient list, in standardised nomenclature and in descending order, following the defined conventions.
The enforcement regulations are on the statute book, the Office for Product Safety and Standards oversees the area, and the Cosmetic, Toiletry and Perfumery Association publishes accessible orientation for brands. Read those before briefing a designer, because a label that has to be redrawn late is the most avoidable cost in a launch.
| Duty | Typical holder | What goes wrong if unassigned |
|---|---|---|
| Responsible person | Brand owner, or manufacturer by agreement | Nobody is accountable to enforcement authorities |
| Safety assessment | Qualified assessor, arranged by agreement | Product cannot lawfully be placed on the market |
| Product information file | Held by the responsible person | Cannot be produced when requested |
| Notification | As agreed, by the responsible person | An administrative gap discovered late |
| Label accuracy | Brand owner, in practice | Reprint, relabel, or withdraw stock |
Source: Framework is this paper's own; the duties derive from the cosmetics regime enforced in Great Britain.
Orientation only, not legal advice. Confirm the position for your specific products with the primary sources and a professional.
Claims on pack are advertising
Everything on the pack that is not mandatory information is marketing, and it is assessed as marketing. A claim printed on a jar is subject to the same expectations as a claim in a paid advert: it must be capable of substantiation and it must not mislead in the way a consumer would understand it.
Two specific traps for small brands:
Medicinal drift. Wording, imagery or a product name that presents the product as preventing or treating a condition can affect how the product is classified. The MHRA sets out how presentation feeds into that assessment. This is covered in when a cosmetic claim becomes a medicinal one.
Free-from and comparative claims. Claims that a product is free from an ingredient can be problematic where they denigrate ingredients that are lawful and safe, or where they imply a safety benefit that is not established. Check the current guidance rather than following what competitors do.
Producer responsibility for the packaging itself
Beyond what is printed on the pack, the pack itself creates obligations. Extended producer responsibility for packaging places duties on businesses that supply packaging, with thresholds determining what applies to whom, and requirements around data collection and reporting.
Two practical consequences for a growing brand. First, you need to be recording packaging data from early on, because retrospective reconstruction is painful. Second, decisions such as adding a secondary carton have a cost consequence beyond the unit price of the carton.
The current guidance is published on gov.uk and the thresholds and requirements change, so check the live guidance rather than a summary. This is an area where small brands are frequently unaware of an obligation until they cross a threshold.
| Decision | Compliance consequence | Cost consequence |
|---|---|---|
| Adding a secondary carton | More printable area for mandatory information | Unit cost and packaging data obligations |
| Reducing pack size | Space pressure on mandatory information | May force a leaflet or a fold-out label |
| Changing a component supplier | Specification and documentation update | Requalification and possible artwork change |
| Adding a variant | Effectively a new product for documentation | Full artwork and minimum order quantity |
| Making an environmental claim | Must be accurate, clear and substantiated | Evidence gathering, and reprint if wrong |
Source: Working model used by this paper, not a measurement.
Producer responsibility thresholds and requirements change. Check current gov.uk guidance rather than relying on a summary written earlier.
The recurring workload, which is the part that surprises people
Packaging compliance is not a one-off gate. It recurs:
- Every reformulation affects the ingredient list, the safety assessment and potentially the claims.
- Every new size or variant is effectively a new product for documentation purposes.
- Every batch needs identification and records.
- Supplier changes can change the composition of a component or a raw material.
- Regulatory updates can restrict ingredients you are using, requiring reformulation and relabelling.
Small brands that treat compliance as a launch task rather than an ongoing function are the ones caught out by an ingredient restriction with a shelf full of stock.
Where the money goes
We will not publish figures for assessment, component or artwork costs, because they vary by product, volume and supplier and any number we printed would be misleading in a specific negotiation. What we can set out is where the costs sit, so they can be budgeted rather than discovered.
One-off per product: formulation and sampling, safety assessment, artwork origination, any tooling. Per production run: components, decoration, filling, minimum order quantities. Recurring: documentation maintenance, packaging data and reporting obligations, reassessment following changes, storage and stock holding.
The line that most often breaks a first budget is minimum order quantities, because they force a decision between a high unit cost on a small run and a large cash commitment on a big one. That trade-off is set out in launching a product line from a service business.
Records, and why they matter more than they appear to
Keep, from the first run: the safety assessment, the product information file location and contents, notification records, supplier specifications for every component and raw material, batch records, artwork versions with dates, and any claim substantiation you rely on.
Two situations make this worthwhile. An enforcement enquiry from trading standards, where being able to produce documents quickly changes the tone of the whole interaction. And a complaint or safety issue, where batch traceability determines whether you are recalling one batch or everything you have ever sold.