Soap and cosmetic labeling: UK and EU

If you have read the US labeling guide, put it down. The argument it is built around (whether your bar is "soap" or a cosmetic, decided by what you claim for it) has no equivalent in the United Kingdom or the European Union.

Here, a product intended to clean the skin is a cosmetic. There is no exemption to keep, no claim that can lose it, and no lighter regime on the other side of the line. That single fact sets a much higher floor, and everything below follows from it.

What being a cosmetic obliges you to do

Four things, none of which is optional. Most of the work you can do yourself; the safety assessment is the part you cannot:

• A Responsible Person. A named legal entity, established in the market, who carries the compliance obligations. Sell your own soap in the UK and that is you. But if you sell into the EU or Northern Ireland from Britain, you need an RP in the EU or Northern Ireland, which is usually a service you buy.
• A Cosmetic Product Safety Report (CPSR). Two parts: Part A, the safety information about the product, and Part B, the safety assessment itself. Part B must be carried out by a person with a qualification in pharmacy, toxicology, medicine or a similar discipline (Article 10(2) of EC 1223/2009). You cannot write that part yourself.
• A Product Information File (PIF). Everything about the product, kept available to the authorities for ten years after the last unit was placed on the market: formula, CPSR, manufacturing method, proof of claims, batch records.
• Notification before you sell. Through the SCPN portal for Great Britain, the CPNP portal for the EU and Northern Ireland. Not a courtesy: the product may not be placed on the market before it is done.

The practical consequence: the first bar you sell legally in the UK or EU costs more than the first hundred in the US. That is the honest headline, and it is why the sensible order is to design the recipe, then get it assessed, then sell, rather than the other way around.

Three markets, one kitchen

Brexit split what used to be a single regime into three, and a UK maker can face all of them at once:

Position as checked on 10 October 2026. Northern Ireland follows the EU regulation under the Windsor Framework while remaining part of the UK market, which is why it appears separately. Regimes here diverge over time, so check before you print labels.

The allergen rule changed on 31 July 2026

This is the most consequential recent change. Commission Regulation (EU) 2023/1545 expanded the list of fragrance allergens that must be named individually on the label. In the regulation's own count, 24 allergens were already labeled and 56 more are added, about 80 in all, with some grouped into a single entry; you will also see the older list counted as 26 and the new one as 82. Any product placed on the EU market from 31 July 2026 must comply, and that means every unit placed from that date, not only new recipes; units placed on the market before then may still be made available until 31 July 2028.

The declaration thresholds are 0.001% for leave-on products and 0.01% for rinse-off, and soap is rinse-off. That number is a share of the finished product, which is not the unit soapmakers think in, so here it is converted:

Calculated for the classic bar at 1,000 g of oils, 5% superfat and a 33% lye solution, with each fragrance weight taken as a share of the cured weight, since that is the product placed on the market. The fragrance calculator does the same conversion for your own batch. It already handles "% of oils" against "% of finished product", which is the same trap in a different context.

Great Britain has not followed

A divergence worth knowing about, because it is the kind of thing that quietly makes a label wrong. Great Britain has not adopted 2023/1545 and still requires individual labeling of the historic 24 allergens only.

So a maker in Britain selling only in Britain works to the old list; the same maker shipping to Dublin, or to Belfast, works to 80. Declaring the fuller list everywhere is the obvious simplification (more information than GB requires is not a breach), and it is what most makers who sell across the border end up doing rather than running two labels.

What must be on the label

Article 19 of EC 1223/2009 and its retained UK equivalent. The ingredient declaration itself works the same way as the US cosmetic one, in descending order of weight, except that here the names are the INCI ones (Aqua, Parfum, Latin botanical names) where the US wants English; and the US guide prints a worked example, with the INCI names alongside, computed from a real recipe, including why sodium hydroxide appears on the label of a soap that contains none.

Two of these are real departures from US practice. The batch number is mandatory, so batch records stop being good practice and become a legal requirement. The printable batch sheet on the first-batch guide covers what to record. And nominal content is the weight at packing, which for soap means deciding when packing happens relative to cure; a bar wrapped at four weeks is still losing water, and the bar count calculator will tell you where it settles.

What it costs, and the formulation consequence

UK CPSR pricing published by assessors, as checked on 31 August 2026: from around £55 for a simple single product such as a plain soap; roughly £189 per report from one established provider, falling to about £98 each in batches; and packages built for small makers covering a base recipe plus several variations.

The number that should change how you formulate is the variant pricing: scent and color variations of an assessed base are commonly £10–£40 each, not a new report, because the core assessment work is shared. That has a direct consequence:

• One base recipe, many scents is dramatically cheaper to keep compliant than five recipes with one scent each.
• Every new base recipe is a new report. Reformulating on a whim has a price attached that it does not have in the US.
• Assess before you scale, not after. Changing the recipe after assessment means paying again.

Which is, conveniently, how a seller should formulate anyway: a base you know well, varied by scent. The regulation just puts a number on the advice.

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