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Guides / Online-only shops

Does an online-only shop still need a label on the soap?

Published 22 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.

Yes. The label duty attaches to the product, not to the shop. Article 19(1) of the cosmetics regulation allows a cosmetic product to be made available on the market only where "the container and packaging" bear the listed particulars "in indelible, easily legible and visible lettering". Nothing in the article turns on how the sale was made. A bar sold from a website and posted to the customer is made available on the market, and the bar in the parcel must carry the particulars, whatever the listing said. The same text applies in Great Britain.

What the online listing is for

The listing is where a customer decides; the label is where the regulation puts the information. Some marketplaces require the ingredient list in the listing as a condition of selling, and giving it there is good practice for anyone with an allergy to check before they buy. It does not discharge Article 19. The seven particulars in Article 19(1), from the responsible person's name and address to the ingredient list, belong on the product the customer unwraps.

Which particulars may sit on the outer packaging only

Article 19 gives two reliefs that matter for a bar of soap. The ingredient list "may be indicated on the packaging alone" (Article 19(1)(g)), so a band or a box can carry it while the bar itself carries nothing. The batch number may appear only on the packaging where the product is too small (Article 19(1)(e)). The other particulars go on the container and the packaging. For soap sold by post, "packaging" is the wrap, band, box or bag the bar is in when it arrives; the outer mailing box is not where the customer looks for it.

When a label really will not fit

Where it is impossible for practical reasons to label the precautions or the ingredient list on the product, Article 19(2) allows them on "an enclosed or attached leaflet, label, tape, tag or card", referred to on the container or packaging by the hand symbol in Annex VII, point 1. For soap and other small products where even that is impossible, Article 19(3) puts the ingredient list on a notice next to the container in which the product is exposed for sale, which is a shop-counter rule and does not help a parcel. In practice a bar sold online has room for a band or a card, and the tool's label sizes start small enough for a single bar.

Loose, unpackaged and made-to-order bars

Article 19(4) leaves the rules for products that are not pre-packaged, or are packaged at the point of sale, to the Member States. In Great Britain regulation 5 of the Cosmetic Products Enforcement Regulations 2013 fills that in: for products not pre-packaged or packaged at the customer's request, the Article 19(1) information goes on the container the product is exposed in or on a notice in immediate proximity; for products pre-packaged for immediate sale, on an attached label, tag, tape or card or an enclosed leaflet, or where that is impossible, on a notice. Those are market-stall and shop-counter rules. An online-only shop is the opposite case: every bar is pre-packaged before it is sold, so the full Article 19(1) label applies.

Related questions

Is putting the ingredients in the online listing enough?

No. Article 19(1) requires the particulars on the container and packaging of the product. A listing can carry them as well, and some marketplaces require that, but it does not replace the label on the product the customer receives.

My bars are wrapped in paper with a band. Where do the particulars go?

The band and the paper are the packaging. Article 19(1)(g) allows the ingredient list on the packaging alone, and Article 19(1)(e) allows the batch number on the packaging alone where the product is too small; the rest of the particulars go on the container and packaging as Article 19(1) requires. Where it is impossible for practical reasons to label the precautions or the ingredient list on the container and packaging, Article 19(2) allows them on an enclosed or attached leaflet, label, tape, tag or card, referred to by the hand symbol in Annex VII.

What if I sell loose bars at a market as well?

Article 19(3) is written for exactly that: for soap and other small products where the ingredient list cannot appear on a label, tag, tape, card or leaflet, it shall appear on a notice in immediate proximity to the container in which the product is exposed for sale. For products that are not pre-packaged at all, Article 19(4) leaves the detailed rules to the Member State; in Great Britain regulation 5(1) of the Enforcement Regulations 2013 puts the Article 19(1) information on the container the product is exposed in or on a notice next to it.

Tell me if this answer changes

Article 19 has not changed in substance for years. If it does, or a Member State or the UK changes its rules for products sold at a distance, we will email you.

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Sources

  • Regulation (EC) No 1223/2009 on cosmetic products, consolidated 18.05.2026, CELEX 02009R1223: Article 19(1), (1)(e), (1)(g), (2), (3) and (4); Annex VII point 1 (the hand symbol)
  • Regulation (EC) No 1223/2009 as it applies in Great Britain (assimilated law), Article 19, legislation.gov.uk, text current to 15 August 2026 (same wording)
  • The Cosmetic Products Enforcement Regulations 2013 (SI 2013/1478), regulation 5(1) and 5(2): products not pre-packaged, packaged at the point of sale, or pre-packaged for immediate sale

The documents this answer rests on. A labelling reference, not legal advice; you remain responsible for your product's labelling.