Labelling Guide for Repacked and Rebranded Products

If you're purchasing bulk products from us to sell under your own brand, one of the most important steps is correctly labelling your items. Whether you're selling cosmetics, home fragrance, or other chemical-based products, your labels must comply with local regulations, be informative, and attractive to your customers.

This guide outlines what you need to know when creating your own labels for resale, both for cosmetic and non-cosmetic products like essential oils, fragrance oils, and candles.

Labelling Cosmetic Products

A cosmetic product is any substance or preparation that is used to enhance or alter the appearance of the body, particularly the face, skin, hair, or nails. These products are typically applied topically and include a wide range of items such as makeup, skincare products, hair care products, fragrances, and personal care products.

Common examples of cosmetic products include foundation, lipstick, eyeshadow, mascara, moisturizers, cleansers, shampoos, conditioners, perfumes, and deodorants. These products are typically available in various forms, such as creams, lotions, powders, gels, sprays, and sticks, to cater to different preferences and application methods. It's important to note that cosmetic products are different from pharmaceutical products, as they are not intended to diagnose, treat, or cure any medical conditions. Instead, they are primarily used for cosmetic purposes to enhance one's appearance and personal grooming.

Example of Cosmetic Product Label

Before designing your labels, it's crucial to familiarize yourself with the legal requirements for cosmetic product labeling in your target market. Laws and regulations may vary between countries or regions. Ensure your labels comply with the guidelines set forth by regulatory bodies such as the EU/UK Cosmetics Regulation (in the European Union), or local regulatory authorities.

Where to register a Cosmetic Product in the UK (if you want to be RP for the product)

In the UK, to sell cosmetic products, you must ensure that your products comply with the UK Cosmetics Regulation. A key part of this is designating a Responsible Person (RP), who is responsible for the product's safety, compliance, and registration. Here’s how it works:

Steps to Register a Cosmetic Product in the UK:

1. Responsible Person (RP) Designation:

   • Every cosmetic product sold in the UK must have a Responsible Person.
   • The RP can be the manufacturer, importer, distributor, or a third-party company authorised by the manufacturer.
   • The RP is responsible for ensuring the product's compliance with UK regulations, including safety assessments and labelling.

2. Notification to the UK Office for Product Safety and Standards (OPSS):

   • The RP must register the cosmetic product on the UK’s Cosmetic Product Notification Portal (UKCPNP).
   • The registration must include details such as product ingredients, labelling information, and a safety assessment.

3. Safety Assessment:

   • A cosmetic product safety report (CPSR) must be completed by a qualified safety assessor before placing the product on the market.

4. Product Labeling:

   • Labels must include mandatory information like the name and address of the RP, ingredient list, batch number, and warnings or usage instructions (if applicable).

UK Responsible Person Requirements:

1. The RP must be established within the UK.
2. They are accountable for compliance with cosmetic regulations, including keeping the Product Information File (PIF) readily accessible to authorities, which contains safety data and product details.

Where to register a cosmetic product in the EU (if you want to be RP for the product)

In the European Union (EU), to register a cosmetic product and act as a Responsible Person (RP), you need to follow the guidelines set out by the EU Cosmetics Regulation (EC) No 1223/2009. Here's the process:

1. Responsible Person (RP) Designation: To sell cosmetics in the EU, a legal entity (either a manufacturer, importer or a third-party company) must be designated as the Responsible Person (RP). This person or entity is responsible for ensuring that the product complies with EU regulations.

2. Cosmetic Product Notification Portal (CPNP): All cosmetic products intended for sale in the EU must be notified through the Cosmetic Product Notification Portal (CPNP), an online platform. This is mandatory before the product is placed on the market.

   Steps to register:

   • Create an account on the EU Commission Authentication Service (ECAS).
   • Access the CPNP via your ECAS account.
   • Submit product details, including its formulation, intended use, and labelling information.
   • Upload the Product Information File (PIF) that contains safety data and other important information.

3. Product Information File (PIF): As the RP, you are responsible for keeping a Product Information File (PIF) for each product you place on the market. The PIF includes:

   • A detailed product description.
   • A Cosmetic Product Safety Report (CPSR).
   • Manufacturing method and Good Manufacturing Practice (GMP) compliance.
   • Proof of the product's effects, if applicable.
   • Labelling and packaging information.

4. Cosmetic Product Safety Report (CPSR): Before the product can be notified, it must undergo a safety assessment. A qualified safety assessor prepares the Cosmetic Product Safety Report (CPSR), which is part of the PIF.

5. Labelling and Claims: Ensure that the product labelling complies with the EU's cosmetic regulations, including ingredient lists and any claims you make about the product (e.g., "anti-ageing" or "moisturising").

6. Compliance with EU Cosmetics Regulation (EC) No 1223/2009: As the RP, you must ensure that the product complies with all aspects of the regulation, including banned substances, permitted ingredients, and labelling requirements.

In summary, to be the RP for a cosmetic product in the EU, you must:

1. Register the product through the CPNP.
2. Maintain a Product Information File (PIF).
3. Ensure the product meets all EU regulatory requirements under EC No 1223/2009.

If you are unfamiliar with the process, some companies specialise in acting as the RP or assisting with compliance.

Labeling Non-Cosmetic Products or Other Chemicals

Non-cosmetics would be other items such as fragrances and essential oils. Non-cosmetics that could be hazardous or not. They could also be raw materials or mixtures.

Labelling non-cosmetic products such as fragrance oils, essential oils, and candles is important for providing essential information to consumers and ensuring compliance with regulatory requirements.

Always check the specific labelling regulations and requirements of your country or region, as they can vary. It is essential to comply with all applicable regulations to ensure the safety and transparency of your products.

1. Product Identity - Name of the products and scent
2. Name, Address and Telephone Number of Manufacturer/Distributor/Reseller - This can be our company or yours if you obtain our CLP documents (usually downloadable from each product page) and are willing to provide these to anyone who'd like to see them. Could be any selling platform such are Amazon, Ebay, Etsy etc.
3. CLP Information if relevant (Signal Words such as "❗️Warning", "⚠️ Danger", Hazard Statements, Pictograms) - This is usually available on each product page to download. CLP labels are intended to be easily understandable and consistent across different hazardous substances and mixtures, helping users and consumers make informed decisions about handling, storage, and disposal of chemicals.
4. UFI Number if a Hazardous Mixture - The UFI is part of the harmonised poison centre notification requirements in the EU. The purpose of the UFI number is to provide a specific reference to a particular mixture, making it easier for poison centres to identify the exact formulation in case of emergencies or incidents involving hazardous substances. It helps ensure that the appropriate advice and guidance can be provided promptly. Provided on each single product page to download.
5. Nominal Quantity - The nominal quantity or volume of the fragrance oil needs to be stated on the bottle. The nominal quantity refers to the amount or volume of the product contained in the bottle. This information is typically provided in standard units such as millilitres (ml) or fluid ounces (fl oz).

Here are some general guidelines for labelling these products for the UK and EU: