If you have read the US labeling guide, put it down. The argument it is built around — whether your bar is "soap" or a cosmetic, decided by what you claim for it — has no equivalent in the United Kingdom or the European Union.
Here, a product intended to clean the skin is a cosmetic. There is no exemption to keep, no claim that can lose it, and no lighter regime on the other side of the line. That single fact sets a much higher floor, and everything below follows from it.
We're soapmakers who read the regulations, not consultants, and this is a map rather than a substitute for advice. The obligations here are heavier than in the US and the penalties are real, so if you intend to sell, budget for a conversation with a safety assessor early rather than late. Our terms say the same about the tools: nothing on this site makes a product lawful.
What being a cosmetic actually obliges you to do
Four things, none of which is optional and none of which you can do for yourself at the kitchen table:
- A Responsible Person. A named legal entity, established in the market, who carries the compliance obligations. Sell your own soap in the UK and that is you — but if you sell into the EU from Britain, you need an RP in the EU, which is a service you buy.
- A Cosmetic Product Safety Report (CPSR). A two-part assessment — Part A the safety information, Part B the assessor's reasoning and conclusion — signed by a suitably qualified safety assessor. You cannot write your own.
- A Product Information File (PIF). Everything about the product, kept available to the authorities for ten years after the last unit was placed on the market: formula, CPSR, manufacturing method, proof of claims, batch records.
- Notification before you sell. Through the SCPN portal for Great Britain, the CPNP portal for the EU. Not a courtesy — the product may not be placed on the market before it is done.
The practical consequence: the first bar you sell legally in the UK or EU costs more than the first hundred in the US. That is the honest headline, and it is why the sensible order is to design the recipe, then get it assessed, then sell — rather than the other way around.
Three markets, one kitchen
Brexit split what used to be a single regime into three, and a UK maker can face all of them at once:
| Selling into | Governed by | Responsible Person | Notify via | Allergens to declare |
|---|---|---|---|---|
| Great Britain | UK Cosmetics Regulation (retained EC 1223/2009) | Responsible Person established in the UK | SCPN portal, before sale | 26 — 2023/1545 not adopted |
| Northern Ireland | EC 1223/2009, under the Windsor Framework | RP in the UK or EU | CPNP — and ingredients also to SCPN | 82 |
| European Union | EC 1223/2009 | Responsible Person established in the EU | CPNP portal, before sale | 82 |
Position as checked on 31 August 2026. Northern Ireland follows the EU regulation under the Windsor Framework while remaining part of the UK market, which is why it appears separately. Regimes here diverge over time — check before you print labels.
The allergen rule changed on 31 July 2026
The most consequential recent change, and almost every soapmaking article on this subject predates it. Commission Regulation (EU) 2023/1545 expanded the list of fragrance allergens that must be named individually on the label from 26 substances to 82. Since 31 July 2026, every new product placed on the EU market must comply; stock already on the market has until 31 July 2028.
The declaration thresholds are 0.001% for leave-on products and 0.01% for rinse-off — and soap is rinse-off. That number is a share of the finished product, which is not the unit soapmakers think in, so here it is converted:
| Fragrance load (% of oils) | Fragrance in the batch | Share of the cured bar | An allergen must be declared above… |
|---|---|---|---|
| 1% | 10 g | 0.82% | 1.23% of the fragrance oil |
| 2% | 20 g | 1.62% | 0.62% of the fragrance oil |
| 3% | 30 g | 2.41% | 0.42% of the fragrance oil |
| 5% | 50 g | 3.95% | 0.25% of the fragrance oil |
| 6% | 60 g | 4.70% | 0.21% of the fragrance oil |
Computed by this site's engine: the classic bar at 1,000 g of oils and a 33% lye solution, costed against the cured weight, since that is the product placed on the market. The fragrance calculator does the same conversion for your own batch — it already handles "% of oils" against "% of finished product", which is the same trap in a different context.
At an ordinary 3% fragrance load, an allergen has to be declared once it makes up 0.42% of the fragrance oil — and at 6% it is 0.21%. Those are very low bars. Citrus oils can run over 50% limonene; linalool, citronellol and geraniol appear at percent levels across most floral and fresh fragrances. So the realistic expectation is not "do I need to declare any?" but "how many" — and with the list now at 82 rather than 26, a scent that needed two names last year may need six. Ask your supplier for an allergen breakdown before you buy, not after you have printed labels; any fragrance house selling into the EU has one.
Great Britain has not followed
A divergence worth knowing about, because it is the kind of thing that quietly makes a label wrong. Great Britain has not adopted 2023/1545 and still requires individual labeling of the historic 26 allergens only.
So a maker in Britain selling only in Britain works to the old list; the same maker shipping to Dublin, or to Belfast, works to 82. Declaring the fuller list everywhere is the obvious simplification — more information than GB requires is not a breach — and it is what most makers who sell across the border end up doing rather than running two labels.
What must be on the label
| Required | The part that catches soapmakers out |
|---|---|
| Name and address of the Responsible Person | Not just yours — the RP’s, and it must be inside the market. |
| Country of origin | If the product is imported into the market. |
| Nominal content | Weight at the time of packing, so cure loss matters. |
| Minimum durability date | Required where it is under 30 months; otherwise a period-after-opening where that concept means anything. |
| Precautions for use | Including any conditions from the safety assessment. |
| Batch number | Mandatory — not optional as it effectively is in the US. |
| The product function | Unless it is obvious from presentation. |
| Ingredients, "INGREDIENTS" heading, INCI, descending order | With fragrance allergens named individually above the threshold. |
Article 19 of EC 1223/2009 and its retained UK equivalent. The ingredient declaration itself works the same way as the US cosmetic one — INCI names in descending order of weight — and the US guide prints a worked example computed from a real recipe, including why sodium hydroxide appears on the label of a soap that contains none.
Two that genuinely differ from US practice. The batch number is mandatory, so batch records stop being good practice and become a legal requirement — the printable batch sheet on the first-batch guide covers what to record. And nominal content is the weight at packing, which for soap means deciding when packing happens relative to cure; a bar wrapped at four weeks is still losing water, and the bar count calculator will tell you where it settles.
What it costs, and the formulation consequence
UK CPSR pricing published by assessors, as checked on 31 August 2026: from around £55 for a simple single product such as a plain soap; roughly £189 per report from one established provider, falling to about £98 each in batches; and packages built for small makers covering a base recipe plus several variations.
The number that should change how you formulate is the variant pricing: scent and color variations of an assessed base are commonly £10–£40 each, not a new report, because the core assessment work is shared. That has a direct consequence —
- One base recipe, many scents is dramatically cheaper to keep compliant than five recipes with one scent each.
- Every new base recipe is a new report. Reformulating on a whim has a price attached that it does not have in the US.
- Assess before you scale, not after. Changing the recipe after assessment means paying again.
Which is, conveniently, how a seller should formulate anyway: a base you know well, varied by scent. The regulation just puts a number on the advice.
SoapmakingToolbox.com · UK / EU soap label checklist
UK / EU label checklist
Soap is a cosmetic here — all of the left column applies before you sell a single bar.
Before you sell
- ☐ Responsible Person named, established in the market
- ☐ CPSR completed by a qualified safety assessor
- ☐ Product Information File assembled and kept
- ☐ Notified — SCPN for GB, CPNP for EU and Northern Ireland
- ☐ Supplier allergen breakdown obtained for every fragrance
- ☐ Batch records started, and kept for ten years
On the label
- ☐ Responsible Person name and address
- ☐ Country of origin, if imported
- ☐ Nominal content — weight at packing
- ☐ Minimum durability date if under 30 months
- ☐ Precautions for use
- ☐ Batch number
- ☐ Function, unless obvious
- ☐ INGREDIENTS, INCI, descending order
- ☐ Allergens named individually — 82 for EU/NI, 26 for GB
EC 1223/2009 (Art. 19) · UK Cosmetics Regulation · (EU) 2023/1545, in force for new products from 31 July 2026 · Windsor Framework. Summary only — not legal advice. Checked 31 August 2026.
The short version
- There is no soap exemption. Soap is a cosmetic, and the US fork doesn't exist here.
- CPSR, Responsible Person, PIF, notification — all four, before the first legal sale.
- Since 31 July 2026 the EU list is 82 allergens, not 26. GB still uses 26.
- At a 3% load, 0.42% of your fragrance oil triggers a declaration. Expect several.
- One base, many scents. Variants cost £10–£40; new recipes cost a new report.