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Selling handmade soap into the EU from the UK: the label

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

Four things change on the label and behind it: who is named as responsible person, where the product is notified, which allergen list you declare against, and the language of the particulars. Germany is the worked example here because it is the most-asked-about market, and because its language rule is written down in one sentence. The ingredient list itself does not change language at all.

A responsible person established in the EU

Article 4(1) of the cosmetics regulation allows a product on the market only where a responsible person is designated within the Community. A soap made in Great Britain is imported into the EU, and for an imported product Article 4(5) makes each importer the responsible person for what they place on the market, adding that the importer "may, by written mandate, designate a person established within the Community as the responsible person who shall accept in writing". A maker in Great Britain therefore needs an EU-established responsible person before the first sale, and the label carries that person's name and address under Article 19(1)(a), with the country of origin, because for the EU the product is imported.

Notification and the safety file

Before placing the product on the EU market, the responsible person submits the Article 13 notification electronically to the Commission (the Cosmetic Products Notification Portal), naming the product, the responsible person's address where the product information file is kept, the country of origin for an import and the Member State of first sale. Article 10 requires a safety assessment and a cosmetic product safety report under Annex I before the product is placed on the market. A UK notification and a UK safety report do not travel automatically; the EU responsible person is accountable for both on the EU side.

The allergen list is longer in the EU

The declaration rule is the same sentence in both texts: substances the Annex III "Other" column requires you to mention are listed alongside "Parfum". The Annexes differ. The EU Annex III, amended by Regulation (EU) 2023/1545, carries more than 80 declarable substances, mandatory for products placed on the market from 1 August 2026. The GB Annex III was never amended by that regulation and carries the older 25, among them Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC), a leftover: the EU prohibits HICC in cosmetics altogether (Annex II, entry 1380; Article 14(1)(a)), and Great Britain's own Annex II carries the same entry, so a soap made with a fragrance oil that contains it cannot be sold in either. So a soap scented with the same oil can need "Parfum, Linalool, Limonene, Terpineol" on the German label, Terpineol being one of the 2023/1545 additions, and only "Parfum, Linalool, Limonene" on the British one. Check the supplier's sheet against both lists; the comparison is on the allergen reference index.

The language of the particulars, Germany as the example

Article 19(5) leaves the language of the nominal content, the durability date, the precautions and the function to "the law of the Member States in which the product is made available to the end user". Germany's Kosmetik-Verordnung, § 4, applies that: those particulars must be given in German. The ingredient list is not among them, because Article 19(6) requires the glossary's common ingredient names, which do not translate: "Sodium Olivate, Aqua, Parfum, Linalool" reads the same in Hamburg and in Hull. What changes is the wording around it: the function, the precautions and the durability wording, in German, with the period-after-opening symbol needing no translation. Other Member States have their own equivalents of § 4; ask the responsible person in each market which languages the label needs.

What stays the same

• The seven particulars of Article 19(1): responsible person, nominal content, durability or period after opening, precautions, batch number, function, ingredient list.
• Descending weight order at the time of addition, the under-1 % rule, colorants last with CI numbers, and "Parfum" for the fragrance.
• The glossary names of Article 19(6), in both texts.
• The soap-specific relief in Article 19(3): where a bar cannot carry the ingredient list on a label, tag, tape, card or leaflet, the list appears on a notice in immediate proximity to the container in which it is exposed for sale.

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