REBOTTLING & REBRANDING
UK LEGAL REQUIREMENTS YOU NEED TO KNOW
🚨 BUYING A PRODUCT & PUTTING IT INTO YOUR OWN PACKAGING DOES NOT AUTOMATICALLY MAKE IT YOURS TO SELL
If you rebottle, refill, relabel, rebrand or sell a product under your own business name, your legal responsibilities can change.
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🧴 COSMETIC PRODUCTS
Examples include:
• Cleansers
• Toners
• Serums
• Moisturisers
• Masks
• Body creams
• Scrubs
• Haircare
• Lip products
• Other products intended for cosmetic use
If you rebrand a cosmetic as your own product:
You may become the Responsible Person.
You cannot simply:
❌ Buy a finished cosmetic
❌ Remove the original label
❌ Add your own logo
❌ Sell it under your own brand
…and assume the original manufacturer’s compliance covers you.
YOU MAY NEED:
✓ A Cosmetic Product Safety Report (CPSR)
✓ A Product Information File (PIF)
✓ Cosmetic GMP compliance
✓ Correct cosmetic labelling
✓ Appropriate safety assessment
✓ UK cosmetic product notification (SCPN)
✓ Evidence supporting cosmetic claims
✓ Correct Responsible Person details
✓ Batch identification and traceability
✓ Appropriate shelf-life / PAO information
The Responsible Person must ensure the cosmetic meets the applicable UK cosmetic requirements before it is made available on the GB market. (GOV.UK)
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🌿 FRAGRANCE & ESSENTIAL OILS
Where an oil or fragrance mixture falls under chemical supply legislation, GB CLP requirements can apply.
REBOTTLING CAN CHANGE YOUR LEGAL RESPONSIBILITIES
If you transfer a substance or mixture from one container into another and place it on the GB market, you can be treated as a re-filler/downstream user.
You may therefore have responsibilities for:
✓ Classification
✓ Hazard labelling
✓ Packaging
✓ Hazard pictograms
✓ Signal words
✓ Hazard statements
✓ Precautionary statements
✓ Required supplier information
✓ SDS information where applicable
✓ Record keeping
✓ Correct packaging and closures
HSE specifically identifies a re-filler transferring substances or mixtures from one container into another as a downstream user. (HSE)
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⚠️ ESSENTIAL OILS ARE NOT “EXEMPT”
Natural does NOT automatically mean:
❌ Non-hazardous
❌ CLP-exempt
❌ Safe to sell without classification
❌ Safe to rebottle without checking the label
❌ Automatically suitable for cosmetic use
Essential oils can contain constituents that affect their hazard classification and labelling.
The classification of substances and mixtures placed on the GB market must comply with GB CLP. (HSE)
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🏷️ YOUR BRAND = YOUR RESPONSIBILITY
Can I change a cosmetic packaging or labelling without permission from the manufacturer?
No, you cannot legally or safely change cosmetic packaging or labelling without permission or taking on formal regulatory accountability.
Altering or replacing branded packaging without a written agreement infringes on trademark laws and can constitute illegal "passing off" or counterfeiting if consumers are misled.
Shift in Liability: By altering the package without the original manufacturer's consent, you absorb 100% of the legal and financial liability if a customer suffers an allergic reaction,
can i rebottle fragrance oils or essential oils without the manufacturers permission or paperwork?
No, you cannot legally rebottle and sell fragrance oils or essential oils without proper paperwork
By changing the bottle, you assume full liability for the product. You are legally required to provide or maintain the following compliance documents:
SDS
CLP labelling
Allergen documents
IFRA certificates
Why we offer whitelabelling?
Whitelabel means we give certain clients, permission to resell certain products under their own branding, while we remain the responsible person for the product. You must keep our details on all labels as required.
🧬We have all CPSR’s in our name
🧬We have all PET/challenge tests in our name
🧬We have all PIF files in our name
🧬We have all products registered on the cosmetics portal and can provide the registration number for each product.
🧬We can produce SDS’s for all finished products
🧬We record all batch numbers of every ingredient used, all supplier documentation and update all our records every time a new batch is made
People acting unlawfully can and will be reported to trading standards
Professional Education • Formulation • Compliance
Educational information only. This poster does not constitute legal advice. Always check the current legislation and obtain appropriate professional regulatory advice for your specific product and business.
Sources: GOV.UK • Office for Product Safety & Standards • Health & Safety Executive