Soap Labelling Requirements UK

A handmade soap label in the UK must carry the Responsible Person's name and address, the weight, the ingredients in INCI form, a batch identifier, what the product does, any precautions for use, the country of origin if imported, and a durability date where one applies. Soap sold for washing skin is a cosmetic product, so it sits under the UK Cosmetics Regulation — not under CLP.

That last point trips up a lot of makers who also pour candles, so it's worth getting straight before anything else.

This covers soap sold as a cosmetic in Great Britain. This is not legal advice.

Soap Is a Cosmetic, Not a CLP Product

If you make both candles and soap, you're working under two different regimes:

• Candles, wax melts, reed diffusers, room sprays → GB CLP. Hazard classification, pictograms, signal words, H and P statements.
• Soap, bath products, skincare → UK Cosmetics Regulation. Ingredient lists, Responsible Person, safety assessment, batch codes.

Finished cosmetics intended for the final consumer are outside CLP's scope. A soap label with a hazard pictogram on it is almost always a sign that someone has applied the wrong rulebook. The two systems ask for genuinely different information, and doing one well tells you nothing about whether you've done the other.

If you make both, you need both — but on different products, not on the same label.

The Required Label Elements

GOV.UK sets out what has to appear. The operative wording is:

"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)'"

Taking those one at a time, in the order they usually cause trouble.

Responsible Person name and address

Every cosmetic on the GB market needs a Responsible Person — a named business, established in the UK, accountable for the product's compliance. If you make and sell your own soap in the UK, that's you.

This has to be a real, contactable UK address, and GOV.UK is explicit about what doesn't count:

"A Responsible Person must have a UK established address to make cosmetic products available in GB. A UK established address does not include mail forwarding or PO box addresses."

So a PO box or a mail-forwarding service is out, not merely inadvisable. A registered-office or accountant's address isn't excluded in the same terms, but because the Product Information File has to be accessible at the address you give, it causes problems if nobody there can actually produce it on request. "Handmade in Sheffield" isn't sufficient either — it doesn't identify anyone. Use an address where the PIF is genuinely reachable.

Ingredients, in INCI form

This is the element makers most often get wrong, because the everyday name and the INCI name are frequently different. The requirement is to:

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

and to

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

Two things follow. First, "olive oil" is Olea Europaea (Olive) Fruit Oil, "lye" is Sodium Hydroxide, and so on — the glossary name, not the shopping-list name. Second, the order is by weight as added, which for cold-process soap means you list what went into the pot, including the sodium hydroxide, rather than trying to describe what the saponified result chemically became.

The ingredient list can go on the packaging alone rather than the container, which is useful for a naked bar sold in a wrap.

Fragrance allergens

If your soap contains any of the listed fragrance allergens above a threshold, they have to be named individually in the ingredient list. The thresholds are:

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

The guidance gives both figures but doesn't define either category or say which products fall into which. For a bar that is washed off in the course of using it, the natural reading is the 0.01% rinse-off figure — but the classification for your product is one of the things the safety assessment settles, so take it from there rather than from a rule of thumb. In practice it rarely changes the outcome: at typical fragrance loads, several allergens — linalool, limonene, citronellol, geraniol, coumarin — clear even the stricter 0.001% figure, and each one that does has to appear by name at the end of the ingredient list.

Your fragrance oil supplier's allergen declaration tells you which are present and at what percentage of the oil. You then work out the concentration in the finished bar.

Batch identifier

A code that lets you trace the bar back to a production run. Format is your choice — a date code, a sequential number, a recipe-plus-date hybrid — as long as it identifies the batch and you keep records that make it meaningful. On placement, the guidance is specific: the code "must be marked on both the primary container and outer packaging", and only "where it is impossible for reasons of size for the batch number to appear on both the primary container and outer packaging, it may appear on the outer packaging alone." There's more on designing one in our guide to creating a cosmetic batch code.

Durability date — when you actually need one

This is where a lot of secondary advice goes wrong, so here's the operative rule.

A date of minimum durability is required where a product is likely to deteriorate up to and including 30 months from manufacture in either of two ways — note the boundary, exactly 30 months is inside the requirement. The two bullets below are the alternative conditions; the sentence then carries on to state the obligation:

"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 (being safe for human health under normal or reasonably foreseeable conditions of use), or
• ceases to fulfil its intended function

must have a date of minimum durability marked on its container and packaging using either the words 'best used before the end of' or the 'Hour-Glass' symbol..."

And crucially:

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

So: if your soap is stable for more than 30 months, you don't need a best-before date. Where the durability date isn't required, the Period After Opening symbol is the alternative marking — the open-jar symbol with a number of months:

"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 universal 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 (in accordance with Article 3 of the Regulation) that is to say for single-use products, products not at risk of deterioration or products which do not open e.g. aerosols."

The practical read for a plain cold-process bar: there's no container for the consumer to open, and a well-cured bar is typically stable well beyond 30 months. Which marking applies is a judgement about your formulation and packaging, and it's one your safety assessor will address — so take the answer from your assessment rather than from a rule of thumb.

Be wary of advice that pairs a short shelf life with a long PAO figure, or vice versa. If the two numbers in a piece of guidance contradict each other, the guidance isn't reliable.

Product function

What the thing is for. "Soap", "cleansing bar", "hand wash" — enough that a buyer isn't guessing. If the name already makes it obvious, that can be sufficient.

Precautions for use

Anything the user needs to know to use it safely — "avoid contact with eyes", warnings tied to specific ingredients, and any restrictions carried over from your safety assessment.

Country of origin

Required if the product is imported into the UK. Soap you make in the UK doesn't need it.

The Safety Assessment Sits Behind the Label

Labelling is the visible end of a longer obligation. Before soap can be made available to consumers:

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

You also have to notify the product through the Submit Cosmetic Product Notification service:

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

The assessment is what tells you the safe fragrance loading, any use restrictions, and often the durability position that drives the labelling choice above. Trying to write the label before the assessment exists usually means rewriting it afterwards. Our guide to soap and cosmetics safety assessments covers what the process involves and what it typically costs.

A Worked Example

A 100 g lavender cold-process bar, made in the UK, sold unwrapped with a paper band:

• Responsible Person: Your Business Ltd, full address
• Weight: 100 g ℮ (the estimate mark is optional but common)
• Function: Cleansing soap bar
• Ingredients: Sodium Olivate, Sodium Cocoate, Aqua, Sodium Shea Butterate, Parfum, Sodium Castorate, Glycerin, Linalool, Limonene, Geraniol
• Batch: LAV-260902
• Precautions: For external use only. Avoid contact with eyes.
• Durability marking: as determined by the safety assessment

The three allergens at the end of that ingredient list are there because they exceed the applicable declaration threshold in the finished bar, not because the fragrance oil contains them at any level.

Common Questions

Does handmade soap need a CPSR in the UK?

Yes. Soap sold as a cosmetic needs its safety checked by a qualified safety assessor before you make it available to consumers, and the product notified through the SCPN service. There's no exemption for small batches or home production.

Do I have to list sodium hydroxide if it's all saponified?

The requirement is to list ingredients in descending order of weight as added. Sodium hydroxide goes into the pot, so the conventional approach is to list it — either directly, or by listing the saponified forms (Sodium Olivate, Sodium Cocoate) that reflect the reacted oils. Your safety assessor will confirm which convention suits your formulation.

Can the ingredient list go on the wrapper rather than the bar?

Yes — the ingredients may be provided on the packaging rather than the container. The batch identifier works differently: 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" to carry it on both. A wrapped bar normally needs the code in both places; a bar too small to take it falls within that exception.

Does soap need CLP hazard labels?

No. Finished cosmetics for the consumer are outside GB CLP. Hazard pictograms belong on your candles and melts, not on your soap.

Related Guides

• Soap and cosmetics safety assessments: what UK makers need to know
• Cosmetic labelling requirements UK: a plain-English guide
• Cosmetic batch codes: what they are and how to create one
• CPSR certification UK: costs, process, and when you need one

Our free Cosmetic Labelling Checker works through the required elements against a label you've drafted.

CraftCert keeps your soap formulations, INCI names and allergen percentages in one place so the ingredient list and allergen declarations come out of the recipe rather than being rebuilt by hand each time. The safety assessment itself 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