Bath Bomb Labelling and Safety Assessments UK

Bath bombs are cosmetic products under UK law, so each formulation needs its safety checked by a qualified safety assessor before sale, a notification through the SCPN service, and a label carrying the Responsible Person, weight, INCI ingredient list, batch identifier, product function and any precautions. They're one of the cheaper products to get assessed, because the formulations are simple and anhydrous.

The thing that catches bath bomb sellers out isn't usually the assessment — it's the food-lookalike rule and the allergen declarations.

This covers bath bombs sold in Great Britain. This is not legal advice.

Yes, They're Cosmetics

A bath bomb is applied to the external body — dissolved in bathwater that contacts skin — for cleansing, perfuming or conditioning. That puts it squarely under the UK Cosmetics Regulation, alongside soap and skincare, and outside GB CLP.

This matters if you also make candles or melts. Your fragranced home-fragrance products carry CLP hazard labels; your bath bombs don't. Same fragrance oil, two different regimes, because one product is a chemical mixture placed on the market and the other is a finished cosmetic for the consumer. Putting a hazard pictogram on a bath bomb is applying the wrong rulebook.

The Safety Assessment

The requirement:

"Before making a cosmetic product available to consumers, its safety must be checked by a qualified safety assessor."

For bath bombs specifically, the assessment tends to focus on:

• Fragrance loading — the safe percentage for a product that disperses into bathwater and contacts a large skin area
• Colourants — whether each is permitted for the use, and at what level. Colourant permissions are a common reason an assessor sends a bath bomb formulation back for adjustment.
• Skin-contact ingredients — clays, botanicals, butters, surfactants
• Physical form — dust and inhalation considerations for powdered products
• Stability — how the product behaves over time in its packaging

Bath bombs tend to sit toward the simpler end of what an assessor prices, because they're anhydrous, single-phase, and formulaically straightforward compared with an emulsion. Assessors also commonly price a range together where the base recipe is shared and only colour and fragrance vary — which for a typical bath bomb line is exactly the case, and is generally cheaper than commissioning each scent as a standalone assessment. Ask any assessor you're quoting whether they offer range pricing before you submit scents separately.

Before you commission it, get your paperwork straight: exact percentages, INCI names for everything, supplier specifications, allergen declarations for each fragrance, and your method. Preparation is the single biggest lever on what you pay. Our cosmetic safety assessment cost guide goes into what drives the quote.

You also have to notify each product before sale:

"you must notify your cosmetic products using the Submit cosmetic product notifications service"

What Goes on the Label

The required elements are the same as for any cosmetic:

"The container and any packaging must be labelled with:

• the name and address of the Responsible Person
• the country of origin if the product is imported to the UK
• the weight or volume
• the date which the cosmetic product can be used until
• any precautions for use
• an identification number (for example batch number)
• what the cosmetic product does
• the ingredients - these can be provided solely on the packaging. Note that nanomaterial ingredients must be followed by '(nano)'"

Three of those need particular care on bath bombs.

Ingredients, in INCI form

Listed using the glossary names, in descending order of weight as added:

"use the name given in the glossary of Common Ingredient names"

"show ingredients in descending order of weight (determined at the time the ingredients are added to the product)"

So sodium bicarbonate is Sodium Bicarbonate, citric acid is Citric Acid, Epsom salt is Magnesium Sulfate, and your oils and butters take their botanical INCI names. Colourants take their CI numbers.

Fragrance allergens

The guidance sets two thresholds:

"The threshold levels for declaration are 0.001% for leave-on products and 0.01% for rinse-off products."

What it doesn't do is define either category or classify product types, and a bath bomb is not an obvious fit for either — it disperses into bathwater that stays in skin contact for the length of a bath, then is rinsed away. Which of the two figures applies to your product is part of what the safety assessment settles, and it's worth an explicit answer rather than an assumption: the two thresholds differ tenfold.

In practice the answer often doesn't change the label. At typical bath bomb fragrance loads several common allergens clear even the stricter 0.001% figure, each of which then has to be named individually at the end of the ingredient list. Your fragrance supplier's allergen declaration gives you the percentages within the oil; you calculate the concentration in the finished bomb.

Durability marking

Here's where a lot of circulating advice is simply wrong, so the operative rule is worth quoting. A minimum durability date is required for:

"A product which is likely to deteriorate up to and including 30 months from the date of manufacture so that it: ceases to satisfy the general safety requirement in Article 3 ... or ceases to fulfil its intended function ... must have a date of minimum durability marked on its container and packaging"

But:

"Dates of minimum durability (best before date) is not mandatory for products with a minimum durability of more than 30 months."

Where a durability date isn't required, the Period After Opening symbol is the alternative:

"The PAO is indicated by a symbol representing an open cream jar, together with the period of time in months or years shown as a number i.e. 12 m."

And the PAO isn't always needed either:

"The PAO symbol will not be necessary where there is no risk of harm to the consumer, as there is no risk of deterioration that could lead to damage to human health ... that is to say for single-use products, products not at risk of deterioration or products which do not open e.g. aerosols."

A bath bomb is a single-use, anhydrous product that generally doesn't have a container the consumer opens and reuses. Whether it needs a durability date, a PAO, or neither, depends on how your specific formulation and packaging perform — and that's a question your safety assessment answers. Take the marking from the assessment.

Be sceptical of any guidance that pairs a short shelf life with a long PAO number. If two figures in the same sentence contradict each other, the source isn't reliable.

The Food-Lookalike Problem

This is the bath-bomb-specific trap, and it's worth reading the actual rule rather than the shorthand version that circulates. The Food Imitations (Safety) Regulations 1989 provide:

"No person shall supply, offer to supply, agree to supply, expose for supply or possess for supply any manufactured goods which are ordinarily intended for private use and are not food but which– (a) have a form, odour, colour, appearance, packaging, labelling, volume or size which is likely to cause persons, in particular, children to confuse them with food and in consequence to place them in their mouths or suck them or swallow them; and (b) where such action as is mentioned in (a) above is taken in relation to them, may cause death or personal injury."

Note the "and" between (a) and (b) — both limbs have to be met. This is not a blanket prohibition on anything food-shaped. It bites where the resemblance is likely to lead someone, particularly a child, to mouth or swallow the product and doing so may cause death or personal injury. Plenty of online advice states the first half as though it were the whole rule; it isn't.

That said, bath products sit uncomfortably close to both limbs. The aesthetic that sells well is often exactly the exposed one — cupcake bath bombs, ice-cream-shaped bath melts, doughnut fizzers, dessert scents in bakery-style packaging — and a concentrated fizzing product that a small child puts in their mouth is not a trivial event. So the practical caution stands even though the legal test is narrower than commonly quoted.

Sensible steps:

• Be most careful with small, realistic food shapes — size and swallowability are what move a design toward limb (b)
• Watch food-mimicking packaging (patisserie boxes, ice cream tubs) as well as the product itself; the regulation names packaging and labelling explicitly
• Reconsider product names that read as edible without qualification
• Where a design leans dessert-like, make the cosmetic identity unmistakable on the packaging

Your safety assessor will usually raise this if the presentation is borderline. It's cheaper to hear it before you've had a thousand boxes printed.

Common Questions

Do bath bombs need a CPSR in the UK?

Yes. A bath bomb is a cosmetic product, and its safety must be checked by a qualified safety assessor before it's made available to consumers. There's no exemption for small batches or home production.

Do bath bombs need CLP labels?

No. Finished cosmetics for the consumer sit outside GB CLP. Hazard pictograms belong on your candles, melts and diffusers, not on bath products.

Can I sell bath bombs without a safety assessment?

No. The requirement applies before the product is made available to consumers, regardless of volume or sales channel.

Do I need a separate assessment for each colour and scent?

Not necessarily. Where a shared base formula varies only by colourant and fragrance, assessors commonly cover the range in one assessment. Confirm the scope before commissioning it, and confirm what a later added scent will cost.

Does the whole ingredient list have to be on the bath bomb itself?

The ingredients may be provided on the packaging rather than the container, which is how most unwrapped bath bombs handle it — a wrap, band, or box carrying the full list. The batch identifier is a different case: it "must be marked on both the primary container and outer packaging", and may appear "on the outer packaging alone" only "where it is impossible for reasons of size for the batch number to appear on both". A bare bomb that genuinely can't carry a printed code is what that exception is for — it turns on size, not on convenience.

Related Guides

• Soap and cosmetics safety assessments: what UK makers need to know
• Cosmetic safety assessment costs in the UK
• Cosmetic labelling requirements UK: a plain-English guide
• Laws on selling homemade beauty products in the UK
• Cosmetic batch codes: what they are and how to create one

Our free Cosmetic Labelling Checker runs a draft label against the required elements.

CraftCert keeps bath product formulations, INCI names and allergen percentages together so the ingredient list and allergen declarations come out of the recipe, and a shared base across scents stays consistent. The safety assessment still goes to a qualified assessor. See pricing.

Sources

• GOV.UK — Making cosmetic products available to consumers in Great Britain
• GOV.UK — Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (Great Britain)
• GOV.UK — Submit a cosmetic product notification
• The Food Imitations (Safety) Regulations 1989, regulation 4 (legislation.gov.uk)