Guide · Compliance

Cosmetic packaging compliance:
US, EU & UK rules explained.

Selling into the US, EU or UK means your packaging has to satisfy real regulation — on labelling, materials and increasingly recyclability. Here's what an indie beauty brand actually needs to know, market by market, in plain English.

By the Vella sourcing team · Updated June 2026 · 9-min read

Short answer

Packaging-relevant rules by market: US — FDA cosmetic labeling rules plus MoCRA (registration, safety substantiation, label information); EU — Regulation (EC) 1223/2009 with CPNP notification, plus PPWR packaging targets on recycled content and recyclability; UK — post-Brexit SCPN notification via OPSS, UK cosmetic labeling, and UK REACH for materials. Across all three: leave label space for required info, keep material certificates (food-contact grade, REACH), and factor in recyclability/PCR mandates. This is general guidance, not legal advice.

United States — FDA & MoCRA

US cosmetics are regulated by the FDA, and the Modernization of Cosmetics Regulation Act (MoCRA) significantly expanded requirements: facility registration, product listing, safety substantiation and adverse-event reporting. For packaging specifically, that means your label must carry the required information (identity, net quantity, ingredients, responsible-party contact, warnings) — so leave enough print area on the pack and carton. Materials in contact with product should be appropriate/food-contact grade where relevant.

European Union — Regulation 1223/2009, CPNP & PPWR

The EU regulates cosmetics under Regulation (EC) No 1223/2009, requiring a Responsible Person, a Product Information File, and CPNP notification before sale. Labelling rules are strict (ingredient list, PAO/period-after-opening symbol, responsible-person address, nominal content). On packaging, the Packaging & Packaging Waste Regulation (PPWR) is now the big driver — progressive targets on recycled content, recyclability and reusability. Choosing PCR and mono-material recycle-ready structures ahead of these targets is smart. See our PCR packaging and refillable systems.

United Kingdom — SCPN, OPSS & UK REACH

Post-Brexit, the UK runs its own regime: notify products via the SCPN (Submit Cosmetic Product Notifications) service overseen by the OPSS, follow UK cosmetic labelling rules (broadly aligned with the EU but with a UK Responsible Person address), and ensure materials meet UK REACH. The UK's Extended Producer Responsibility (EPR) for packaging also affects reporting and favours recyclable formats.

Australia — AICIS, the ACCC, and the line most brands miss

Two bodies, and they do different things. AICIS (the Australian Industrial Chemicals Introduction Scheme) is a business registration for introducing industrial chemicals: you register your business before you import, and you make an annual declaration of what you introduced. AICIS does not set labelling, safety data sheet or packaging requirements. Cosmetic labelling and product safety sit with the ACCC. Brands routinely conflate the two and prepare for the wrong one, and it is a common cause of delay at first import.

What has to be on the pack. The Australian importer's name and address must appear on the packaging — the single line most often missed by brands sourcing from overseas, because the domestic version of the same artwork does not carry it. Ingredients must be listed by INCI name in descending order of concentration, and mandatory information must be in English.

Sustainability. APCO (the Australian Packaging Covenant Organisation) publishes sustainable packaging guidelines. It is a covenant rather than a statute, so treat it as an expectation to design toward rather than a rule to clear — recycle-ready mono-material formats and PCR content are the usual routes. Format-specific guidance is on our packaging page for Australian beauty brands.

The pattern across all four markets: it is label real estate, not the container

Read the four regimes side by side and the same thing keeps happening. Almost none of the packaging burden lands on the bottle. It lands on the label.

  • United States — a domestic address, phone number or electronic contact for adverse event reports, and probable fragrance allergen disclosure to come.
  • European Union — the Responsible Person's details, the full INCI list, and PPWR-driven material and recyclability information.
  • United Kingdom — a UK Responsible Person address, and a “Recycle” / “Do not recycle” mark once that requirement lands.
  • Australia — the importer's name and address, INCI in descending order, in English.

Which turns compliance into two practical packaging decisions rather than a legal project. First: does the format you chose have room? A 15 ml eye serum and a 500 ml body wash face the same list of mandatory text, and only one of them has the surface area for it comfortably. Second: how long does this print run have to last? Requirements arriving in 2026 and 2027 mean a large label order placed today can become a reprint — and a reprint costs more than the headroom would have.

We are a packaging sourcing partner, not a regulatory adviser, and we will not pretend otherwise. What we can do is make sure the container you choose has space for what your market requires, and that you do not pay twice for the same label.

What this means for your packaging choices

RequirementPackaging implication
Mandatory label informationLeave enough print area on pack and carton; a tiny pack may need a peel-back or outer carton
Material safety (food-contact / REACH)Source certified materials; keep the certificates on file
Recycled-content & recyclability targetsFavour PCR and mono-material recycle-ready structures, with GRS certificates
Period-after-opening (EU/UK)PAO symbol must be printed on the pack
Where Vella fits

Vella sources packaging with the material certificates your market requires (food-contact grade, REACH, PCR/GRS), keeps enough label area in the design for mandatory information, and advises on PPWR / EPR-friendly formats. Partner factories operate to ISO 22716 / GMP standards. We don't provide legal advice — but we make sure the packaging side is compliant-ready. See our market pages for the US, EU and UK.

This guide is general information, not legal advice. Confirm current requirements with a qualified regulatory advisor for your specific products and markets.

What does cosmetic packaging compliance actually require of the packaging itself?
Across the US, EU, UK and Australia, almost none of the burden lands on the container — it lands on the label. Each market adds mandatory text: a US contact route for adverse event reports, EU and UK Responsible Person details, a UK recycling mark, the Australian importer's name and address, and a full INCI list. So compliance becomes two packaging decisions: does the format you chose have room for that text, and how long does this print run have to last before a new requirement makes it obsolete.
Does AICIS approve my cosmetic packaging for Australia?
No. AICIS is a business registration for introducing industrial chemicals — you register before importing and make an annual declaration of what you introduced. AICIS does not set labelling, safety data sheet or packaging requirements. Cosmetic labelling and product safety are regulated by the ACCC. The two are frequently confused, and preparing for the wrong one is a common cause of delay at first import.
What does MoCRA mean for my cosmetic packaging in the US?
MoCRA (the Modernization of Cosmetics Regulation Act) expanded US cosmetic rules to include facility registration, product listing, safety substantiation and adverse-event reporting. For packaging, ensure your label carries all FDA-required information (identity, net quantity, ingredients, responsible-party contact, warnings) — so design in enough print area — and use appropriate product-contact materials.
Do I need to notify cosmetic products before selling in the EU or UK?
Yes. The EU requires CPNP notification under Regulation 1223/2009, with a Responsible Person and Product Information File. The UK requires notification via the SCPN service overseen by the OPSS, with a UK Responsible Person. Both have strict labelling rules including the period-after-opening symbol.
How does EU PPWR affect my packaging choices?
The EU Packaging and Packaging Waste Regulation sets progressive targets on recycled content, recyclability and reusability. In practice, choosing PCR (post-consumer recycled) materials with third-party GRS certificates and mono-material recycle-ready structures ahead of these deadlines keeps your packaging compliant and future-proof.
What packaging certificates should I keep on file?
Typically: material safety/food-contact-grade certificates for product-contact components, REACH compliance for materials sold in the EU/UK, and PCR content certificates (GRS or equivalent) for any recycled-content claims. Vella provides these with the relevant orders so your claims are defensible.
Questions

Frequently asked

What does cosmetic packaging compliance actually require of the packaging itself?
Across the US, EU, UK and Australia, almost none of the burden lands on the container — it lands on the label. Each market adds mandatory text: a US contact route for adverse event reports, EU and UK Responsible Person details, a UK recycling mark, the Australian importer's name and address, and a full INCI list. So compliance becomes two packaging decisions: does the format you chose have room for that text, and how long does this print run have to last before a new requirement makes it obsolete.
Does AICIS approve my cosmetic packaging for Australia?
No. AICIS is a business registration for introducing industrial chemicals — you register before importing and make an annual declaration of what you introduced. AICIS does not set labelling, safety data sheet or packaging requirements. Cosmetic labelling and product safety are regulated by the ACCC. The two are frequently confused, and preparing for the wrong one is a common cause of delay at first import.
What does MoCRA mean for my cosmetic packaging in the US?
MoCRA (the Modernization of Cosmetics Regulation Act) expanded US cosmetic rules to include facility registration, product listing, safety substantiation and adverse-event reporting. For packaging, ensure your label carries all FDA-required information (identity, net quantity, ingredients, responsible-party contact, warnings) — so design in enough print area — and use appropriate product-contact materials.
Do I need to notify cosmetic products before selling in the EU or UK?
Yes. The EU requires CPNP notification under Regulation 1223/2009, with a Responsible Person and Product Information File. The UK requires notification via the SCPN service overseen by the OPSS, with a UK Responsible Person. Both have strict labelling rules including the period-after-opening symbol.
How does EU PPWR affect my packaging choices?
The EU Packaging and Packaging Waste Regulation sets progressive targets on recycled content, recyclability and reusability. In practice, choosing PCR (post-consumer recycled) materials with third-party GRS certificates and mono-material recycle-ready structures ahead of these deadlines keeps your packaging compliant and future-proof.
What packaging certificates should I keep on file?
Typically: material safety/food-contact-grade certificates for product-contact components, REACH compliance for materials sold in the EU/UK, and PCR content certificates (GRS or equivalent) for any recycled-content claims. Vella provides these with the relevant orders so your claims are defensible.
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