Guides / EU soap labels

EU soap label requirements, explained for makers

Published 5 July 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.

Handmade soap sold in the EU is a cosmetic product, and its label is governed by Regulation (EC) No 1223/2009. The rules are specific but not mysterious: seven mandatory particulars on the container, and an ingredient list with exact naming and ordering rules. This guide walks through them, with the 2026 fragrance-allergen change makers keep getting caught by.

The seven things Article 19 puts on your label

Article 19(1) requires the container and packaging to carry, in indelible, easily legible and visible lettering:

1. The responsible person's name and address (and the country of origin for imported products).
2. The nominal content at the time of packaging, by weight or volume (packs under 5 g / 5 ml, free samples and single-application packs are excepted).
3. A date of minimum durability ("best used before the end of"), or, for products lasting more than 30 months, the period-after-opening symbol with a time in months or years.
4. Particular precautions for use, at least those from Annexes III to VI that apply to your ingredients.
5. The batch number or a reference identifying the product (packaging only, if the product is too small).
6. The product's function, unless it is clear from presentation (a bar of soap usually speaks for itself).
7. The ingredient list, which gets its own rules below.

The ingredient list rules

The list must be preceded by the word "Ingredients", and may appear on the packaging alone. The rules that trip makers up:

• INCI names, not kitchen names. Ingredients are named using the EU glossary of common ingredient names (Implementing Decision (EU) 2025/1175, in application from 30 July 2026): olive oil in a lotion is "Olea Europaea Fruit Oil", and saponified in a cold-process bar it is conventionally declared as "Sodium Olivate". The glossary binomial carries no parenthetical common name. See our oil INCI reference.
• Descending order of weight, measured at the time the ingredients are added. Ingredients under 1% may then be listed in any order after those above 1%.
• Fragrance is "Parfum". Perfume and aromatic compositions and their raw materials, including essential oils, are declared by the collective term "parfum" or "aroma", never by their trade or botanical names alone.
• Allergens over threshold are named individually. Substances listed in Annex III with a declaration condition must appear in the list in addition to "Parfum" once they exceed 0.001% in leave-on or 0.01% in rinse-off products, summed across every fragrance source. Soap is a rinse-off product. The declarable list is what changed in 2026: Regulation (EU) 2023/1545 took it from the familiar 26 (24 still in force by 2023) to 81, some essential oils among them (lavender oil is declared as "Lavandula Oil/Extract"), mandatory for new products from 1 August 2026. The full current list, with CAS numbers, is in our fragrance-allergen reference.
• Nanomaterials and colorants have their own conventions: nano ingredients are followed by "(nano)", and colorants may be listed in any order after the other ingredients using CI numbers ("may contain" / "+/-" is allowed for shade ranges of decorative cosmetics).

Soap's small-product concession

Article 19(3) names soap directly: for soap, bath balls and other small products where it is impossible for practical reasons to put the ingredient list on a label, tag, tape, card or enclosed leaflet, the list must instead appear on a notice in immediate proximity to the container where the soap is offered for sale. Selling naked bars at a market stall is workable for the list, which just has to be right there with them. Article 19(3) covers only the ingredient list: for products that are not pre-packaged, Article 19(4) leaves the rules for the other particulars to each Member State.

Selling outside the EU?

• Northern Ireland follows the current EU rules, including the 81-entry allergen list.
• Great Britain retains the older assimilated regulation: the shorter 25-entry allergen list still applies, and it diverges in both directions: GB has not adopted the 2023 additions, and GB's Annex III still carries the old declaration row for HICC, although HICC is prohibited in cosmetics in both (Annex II, entry 1380, in the EU text and the GB text alike).
• United States: true soap sold only as soap, without cosmetic claims, is exempt from FDA cosmetic ingredient labelling (21 CFR 701.20). Make a cosmetic claim ("moisturising") and the full 21 CFR 701.3 list is required, with fragrance declared collectively as "Fragrance" and no individual allergen listing in force yet. The US soap label guide covers the rest of a US label.

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