What Must Be Printed on a Gel Polish Bottle: EU Labelling in Practice
Nine elements an EU-compliant nail gel label has to carry, the ones factories get wrong most often, and the small-pack rules that are not an exemption.
Short answer: an EU-market gel polish label needs nine things: the Responsible Person's name and address, country of origin, nominal content, a durability date or PAO symbol, required warnings, batch number, product function, the full INCI list, and the language of the member state where it sells. Nano ingredients also carry a "(nano)" suffix. Miss one and the product is mislabelled, however good the gel is.
The nine elements, in the order an assessor checks them
| Element | What it looks like on the bottle | The mistake we see most |
|---|---|---|
| Responsible Person | "Brand X, street, city, postcode, EU country" | Only the Chinese factory address printed — a non-EU address is not a valid RP |
| Country of origin | "Made in China" | Left off imported product because the brand assumed it was optional |
| Nominal content | "15 ml" | Printing the bottle size when the fill is 12 ml |
| Durability or PAO | "Best before 2029-03" or the open-jar symbol with "12M" | Both at once, or no date on a product that needs one |
| Warnings | "For professional use only. Can cause an allergic reaction." | Translating the sentence but dropping "professional use only" |
| Batch number | "L26A14" on the bottle, not just the carton | Batch only on the outer box, so a complaint cannot be traced |
| Function | "UV/LED gel polish" | Assuming the brand name tells the user what the product is |
| Ingredients | INCI list, descending order above 1%, colourants by CI number | "May contain" pigments listed without CI numbers |
| Language | Official language(s) of the selling market | English-only label shipped into France or Spain |
Why the INCI list is the part buyers get wrong
Ingredients are listed in descending order of concentration down to 1%, after which they may appear in any order. Colourants may be listed in any order after the other ingredients, and pigments used in a shade range are normally declared as "may contain" followed by CI numbers. Fragrance allergens above 0.001% in leave-on and 0.01% in rinse-off products have to be named individually. A gel polish INCI list that stops at "may contain" without CI numbers is not a list — it is a placeholder.
The "(nano)" suffix is not decoration
Under Regulation (EC) No 1223/2009, any ingredient present in nano form must be followed by the word "(nano)" in the ingredient list. Titanium dioxide (CI 77891) and silica are the two ingredients in nail gel that most often trigger the question, because their primary particles sit far below 100 nm even when the aggregates do not. Whether the suffix is required depends on the particle size actually used, which is why a nano declaration and the label have to be written from the same data.
Small packs are not an exemption
The Regulation does allow practical derogations for very small packages — some information can move to a leaflet, tag or notice accompanying the product. It does not allow the Responsible Person, the nominal content, the batch number or the required warnings to disappear. If you are launching a 5 ml mini or a sample vial, decide the derogation route with your assessor before the artwork goes to print, not after.
Claims sit on top of labelling
Labelling tells the buyer what is in the bottle; claims tell them what it does. Claims must be supported by evidence under Article 20 and the common criteria in Regulation (EU) No 655/2013. "Non-toxic", "hypoallergenic", "organic" and "free from" all need substantiation, and a claim that contradicts the ingredient list is a straightforward compliance failure — a "HEMA-free" sticker on a formula that contains HEMA is the version of this we see most. Our EU compliance guide covers which substances are restricted and which are prohibited.
What a factory needs from you to print the label
- Brand name, plus the name and full postal address of the Responsible Person inside the EU.
- Target market and the language or languages required there.
- Fill volume you want declared, which should match what the filler actually puts in the bottle.
- Shelf life position: best-before date, or PAO if the product is stable beyond 30 months.
- Whether the product is professional-use or consumer, because that changes the warning block.
- Any claim you intend to make, with the evidence behind it.
Send us your label artwork and target market and we will mark it against these nine points before you print — it is cheaper than reprinting a run of cartons.
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