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What EU labeling elements are required for shampoo and conditioner (INCI, PAO, batch, warnings)?

For shampoos and conditioners in the EU, mandatory labeling includes INCI list, PAO symbol with duration if under 30 months, batch code, and applicable warnings. We ensure compliance during production and support with documentation.

EU buyer view Launch planning Updated: February 7, 2026
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Best for
US brand owners, Amazon/FBA sellers, distributors, and private label buyers
Core intent
Who submits, what data is needed, and how to plan timelines before production

Quick Answer (for busy buyers)

Here’s the buyer-first summary. If your brand name is on the label, you usually act as the responsible person and must ensure the listing is submitted and kept current.

  • Under EU Regulation (EC) No 1223/2009, shampoo and conditioner labels must display INCI ingredients in descending order, PAO symbol with months if shelf life after opening is under 30 months, batch code for traceability, and warnings like ‘avoid contact with eyes’.
  • We review these elements during the sampling stage to prevent rework.
  • Our MOQ for hair care is typically 10,000 units per SKU, which optimizes label printing costs and ensures batch consistency.
  • Sampling takes 3-4 weeks, including label design approval and initial compliance checks.
  • For testing, we conduct microbial hold-time tests and label adhesion tests under humid conditions to prevent bubbling.
  • We provide technical documentation support, such as Product Information Files (PIF), but do not guarantee regulatory approval as final compliance rests with the brand.
  • Packaging must fit label dimensions precisely; we recommend airless pumps or tubes to reduce leakage risks during shipping.
  • Lead time for production is 8-10 weeks after sampling, with an additional 1-2 weeks for custom label printing.
  • We advise sharing target launch dates early to align with QA checkpoints and document submission timelines.
Buyer outcome
A launch-ready compliance plan: inputs collected, roles assigned, and update cadence defined.
Most common blocker
Missing facility information + inconsistent ingredient/label snapshots across SKUs.
⚠️
This page is a practical buyer guide. For definitive requirements and updates, use FDA resources and qualified regulatory counsel.
  • Our team will answer your inquiries within 8 hours.
  • Your information will be kept strictly confidential.

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