Making and scaling balms

What are the cosmetic labelling requirements in Australia?

The 2020 Cosmetics Information Standard section by section, plus the trade measurement and Poisons Standard rules that reach a balm label, with the 15 g exemption.

Australian law asks a cosmetic label for one thing above all: a list of ingredients on the container, set by the Consumer Goods (Cosmetics) Information Standard 2020 (F2020L01469), made under section 134(1) of the Australian Consumer Law. Ingredients at 1% or more go in descending order by volume or mass, those under 1% in any order, colour additives last, with flavour and fragrance allowed as a single word. A pack of 15 g or more also needs a metric net quantity and an Australian packer's name and address under the trade measurement rules, and a balm carrying enough camphor, wintergreen or cinnamon oil becomes a scheduled poison with its own labelling.

Short answer

Every balm: an ingredient list, English or INCI names, prominent and clearly legible, in the order section 7 sets. No allergen names, batch code or expiry date are required. From 15 g up: net quantity in grams on the front, at least 2.0 mm high on a small pack, plus a street address in Australia for the packer. Under 15 g, as with a 4.25 g lip tube, the list alone is the legal minimum.

  • F2020L01469, never amended
  • 1% or more: descending order
  • "Flavour" and "fragrance" allowed
  • Under 15 g: no net quantity rule
  • Camphor up to 12.5% unscheduled
Not legal advice

Trebalm is a reference site, not a law firm, and this page is orientation for a small maker rather than legal advice. It quotes the information standard and its explanatory statement, the National Trade Measurement Regulations 2009 (compilation 8) and the Poisons Standard of October 2026, all from the Federal Register of Legislation. The ACCC's own guidance pages could not be fetched for this page. Last checked 25 October 2026.

Three instruments, one label

The law firm and retailer summaries that rank for this question merge three instruments into one list. They come from different Acts, have different exemptions, and one drops away entirely on a small lip balm. AICIS registration of the business is a fourth regime with nothing to say about the label; it is covered in notification portals.

Every label element for an ordinary cosmetic balm sold in Australia, the provision that requires it, and whether it applies to a 4.25 g lip tube and a 30 g tin. Texts as on the Federal Register of Legislation in October 2026.
ElementProvision4.25 g lip tube30 g tin
Ingredient list, in the set orderInformation Standard s. 7(1) or (2)YesYes
Prominent, clearly legible, English or INCI namesInformation Standard s. 8YesYes
Net quantity by mass, on the principal display panelNTMR regs 4.9 to 4.13No, under 15 g (Sch. 4, item 5.3)Yes
Packer's name and Australian street addressNTMR reg. 4.7No, under 15 gYes, unless imported prepacked (reg. 4.8)
Poison schedule labellingPoisons Standard, via state and territory lawOnly if a substance crosses its thresholdSame
Fragrance allergen names, batch code, expiry dateNone of the threeNot requiredNot required

The last row is where Australia parts company with its neighbours: New Zealand requires a batch code, as set out in New Zealand cosmetic labelling, and the EU requires allergen names. Print a batch code anyway, for the reasons in batch records.

Which products the information standard covers

Section 6 defines a cosmetic product as "a substance or preparation intended for placement in contact with any external part of the human body", including the mucous membranes of the mouth, with a view to purposes that include "maintaining it in good condition" and "protecting it". Every balm fits. The explanatory statement prints the ACCC's reading of the definition, which names "Products intended for application to the lips without SPF sunscreen" and, separately, lip products "with SPF sunscreen that comply with the Therapeutic Goods Act 1989". So an SPF lip balm still carries an ingredient list under this standard; the sun claim itself is discussed in SPF in lip balm.

Section 5 sets the reach. The standard applies to cosmetics "manufactured in Australia and intended to be used in Australia" or "imported into Australia", and does not apply to:

  • Therapeutic goods (s. 5(2)(a)). A balm sold to treat a condition goes to the TGA instead, which is why the claim matters more than the formula; see cosmetic versus drug claims.
  • Free samples and testers of a cosmetic product (s. 5(2)(c) and (d)). A market stall tester tin needs no list; a tin you sell does.
  • Export only goods, per the explanatory statement: cosmetics "manufactured in Australia for export only".

There is no size, turnover or hobby exemption. The standard binds a kitchen maker selling ten tins exactly as it binds a multinational.

The ingredient list: order, and the one percent line

Section 7(1) is the default: the ingredients "must be listed" on the container, or on the product itself if it has no container, "in descending order by volume or mass". Section 7(2) is the alternative almost every label uses:

  1. Ingredients at 1% or more, colour additives excepted, "in descending order by volume or mass".
  2. Ingredients under 1%, colour additives excepted, "in any order".
  3. Colour additives, "in any order".

The basis is your choice, volume or mass; a balm is made by weight, so mass matches your batch sheet. The list goes on the "container or wrapper in which the product is packed" (s. 6), so a list on a bag you hand over at the stall does not cover the tin.

Exactly 1% belongs in the ordered part

The instrument says "1% or more" for the ordered group and "less than 1%" for the free group. The explanatory statement paraphrases the first as "greater than 1%", and some summaries copy it, but the instrument governs: an ingredient at exactly 1% goes in descending order. New Zealand draws the line the same way. Canada lets ingredients at "1% or less" go in random order, as covered in Canadian cosmetic labelling.

English names or INCI names

Section 8(2) says the names "must be either their English names or their International Nomenclature Cosmetic Ingredient names", and 8(3) allows a second list in another language. Summaries that say Australia "requires INCI" are wrong: "Beeswax" is a lawful Australian name. INCI is still the better choice if the tin will also go to New Zealand or Canada, and the INCI list builder keeps names consistent across a range.

Section 8(1) requires the list to be "prominently shown" and "clearly legible", which the explanatory statement explains as "able to be easily read by a person with normal vision". No type height is set.

Worked on the site's usual 4.25 g lip balm, castor oil 40%, beeswax 25%, shea butter 20%, jojoba 13.5%, peppermint flavour 1% and tocopherol 0.5%, two lawful Australian lists are:

  • "Ingredients: Castor Oil, Beeswax, Shea Butter, Jojoba Oil, Flavour, Tocopherol."
  • "Ingredients: Ricinus Communis (Castor) Seed Oil, Cera Alba, Butyrospermum Parkii (Shea) Butter, Simmondsia Chinensis (Jojoba) Seed Oil, Aroma, Tocopherol."

The flavour sits fifth because at exactly 1% it is in the ordered part; the Canadian version puts "Aroma" last. How a buyer decodes either list is in reading a balm label.

Flavour and fragrance: one word is enough

Section 7(7) lets a flavour be shown by "the word 'flavour', 'flavours', 'aroma' or 'aromas'" or by its ingredients, and section 7(8) does the same for "fragrance", "fragrances", "parfum" or "parfums". A fragrance is "a substance used solely to impart an odour" (s. 6), and the explanatory statement adds that these are "the only ingredients which may be generically identified".

Nothing in the standard asks for individual fragrance allergens. A balm with 1% lavender oil can read "Fragrance" in Australia, where the same tin in Canada or the EU must also name the linalool and limonene above 0.001% of the product. Naming them anyway is allowed, and lets one label serve every market; the thresholds are in fragrance allergen labelling.

The collective word has a limit: "solely to impart an odour" does not cover camphor or eucalyptus added to a chest rub as an active. Name them.

Colour additives, "may contain" and incidental ingredients

For tinted balms, section 7(4) lets the list name a colour additive absent from this batch if it is used "for the purposes of colour matching", or in some but not all of a range "available in different shades" (s. 7(5)). The list must flag it with "may contain" or the symbol "+/-" before the name (s. 7(6)).

One printed label then serves a shade range: "Ingredients: Castor Oil, Beeswax, Shea Butter, Jojoba Oil, Tocopherol, may contain: CI 77491, CI 77891, Mica." Shade building is in tinted lip balm.

Section 7(9) excuses an "incidental ingredient", one with "no technical or functional effect" present "in insignificant levels". Tocopherol you add to slow rancidity has a function and is listed.

When the list will not fit: section 7(3)

If the list cannot go on the container "because of its size, shape or nature", section 7(3) requires it "in another way that ensures that a consumer can be informed". There is no area threshold. The explanatory statement's examples include a list "displayed on the shelf near where the product is sold", and "leaflets, pamphlets, brochures, labels, manuals, swing-tags, display panels, posters or similar methods" attached to, provided with or "prominently displayed alongside" the product.

The small pack routes in three neighbouring regimes. Australia from s. 7(3) and its explanatory statement; Canada and New Zealand as set out on Trebalm's pages for each.
QuestionAustraliaCanadaNew Zealand
TriggerList cannot go on the pack because of size, shape or naturePack too small for a legible listSmall pack; display only under 80 cm2 total surface
Shelf sign or display panelYes, in the explanatory statementNoYes, under 80 cm2
Swing tag, leaflet, pamphletYesTag, tape or card; leaflet where a tag is impracticalInsert or point of sale leaflet
Website named on the packNot named in the text or the explanatory statementYes, with a statement on the outer labelNot named on Trebalm's page

A standard lip tube is not such a pack: the list above runs to about 80 characters and fits a wrap label legibly. Section 7(3) is for lipstick bullets and tiny pots, not crowded artwork. If the label is driving the container choice, lip balm tube versus tin compares the space each gives.

Online sellers should note that every example is physically present with the product; no website route is named.

Trade secrets: the section 9 permission

Section 9 is the only way to keep a name off the list. On request from the manufacturer or importer, "the Minister may, by notifiable instrument, give permission" for an ingredient to appear as an "other ingredient", if satisfied that revealing the name "would prejudice a trade secret" and that the ingredient "is unlikely to be harmful to a consumer".

It is a poor fit for a balm maker. The permission is per ingredient, decided by a Minister and published, and a refusal goes to the Administrative Appeals Tribunal under section 10. A blend of carrier oils and beeswax has no secret name to protect. Section 12(2) keeps alive permissions granted under the 1991 regulations.

The only percentage the standard asks for

The standard requires no percentages on a balm. The explanatory statement says it plainly: "The quantity or percentage of each ingredient does not need to be declared unless the product is classified as a hand sanitiser in accordance with section 11."

Section 11 applies only to cosmetic hand sanitiser "that contains alcohol as the primary active ingredient": alcohol "as a percentage (%), by volume per volume (v/v)", plus five warnings including "Keep out of reach of children" and "For external use only". It is why the 1991 rules were remade during the COVID-19 emergency, and it never reaches a balm.

If you print a percentage anyway, such as "20% shea butter", read regulation 4.29(2) of the trade measurement regulations first. It makes it a "prohibited expression" on a package to use an expression relating to "any ingredient or component of the product" that "cannot be tested for its truth by testing the product".

The transitional rule, and why the text is still current

The standard commenced on 25 November 2020. Section 5(1) applies it to products made "after the end of 180 days after the commencement", which ran out in late May 2021, and section 12(1) let earlier stock comply with either it or the 1991 regulations. The explanatory statement says it "carries over all of the requirements of the repealed information standard", so only the hand sanitiser rule was new.

The transition is spent, and the instrument has never been amended: the Federal Register lists one version, compilation 0, current at October 2026. The clause numbers on this page are the ones in force.

Net quantity and address: the trade measurement rules

The net quantity and packer's details come from the National Trade Measurement Regulations 2009, made under the National Measurement Act 1960. The cosmetics explanatory statement points there, listing "The National Measurement Institute" and "The Poisons Standard" among the "other government standards" a cosmetic may need to meet.

The 15 g exemption

Schedule 4 lists packages exempt from Divisions 4.3 and 4.4, the name and address rule and the measurement rules. Item 5.3 is "an article that is: (a) packed in a quantity less than 15 g or 15 mL", unless it is one of a few exceptions, among them therapeutic goods. A cosmetic lip balm is not one.

So a 4.25 g tube, a 5.5 g tube and a 10 ml slider tin are outside both rules, and a 15 g tin, not being "less than", is inside. Regulation 4.4(3) adds a catch: an exempt package that is marked with a measurement anyway must mark it the compliant way.

Mass, not millilitres

Regulation 4.13(3) requires a "solid", "semi-solid or partly solid and partly liquid" product to be marked "by reference to mass", in grams up to 1,000 g (Schedule 6). Schedule 5 lets "Skin cream in jars" use mass or volume, and a liquid lip oil goes by volume (reg. 4.13(2)). Millilitres are reserved for "a liquid". A tin sold as "15 ml" is a capacity; the balm in it is declared in grams.

Where it goes and how big

The marking goes on the principal display panel, "the part of the package that is most likely to be displayed under normal and customary conditions of display" (regs 4.1, 4.10), close to the product name and read in the same direction, at least 2 mm from the edge and "separated by at least 2 mm in all directions from other graphic matter or copy" (reg. 4.11). On a cylinder it must sit within "one-sixth of the circumference" of the panel's centre line. No more than three significant figures (reg. 4.14): "4.25 g", not "4.250 g".

Trade measurement marking for common balm packs under NTMR regs 4.12, 4.36 and Schedule 4. Pack dimensions are typical examples; the tolerance column is calculated here, before the rounding the regulation's table applies.
PackLargest dimensionMarking required?Printed charactersTolerable deficiency
4.25 g lip tube, 16 by 68 mm68 mmNo, under 15 g2.0 mm if marked9%, 0.38 g
10 ml slider tin, 7 to 9 gunder 120 mmNo, under 15 g2.0 mm if marked9%
15 g tinunder 120 mmYes2.0 mm9%, 1.35 g
30 g tinunder 120 mmYes2.0 mm9%, 2.7 g
60 g tinunder 120 mmYes2.0 mm4.5 g
120 g jarunder 120 mmYes2.0 mm4.5%, 5.4 g

Printed characters must contrast with the background and be at least 2.0 mm high on a pack up to 120 mm in its largest dimension, rising to 2.5, 3.3 and 4.8 mm for larger packs (reg. 4.12). Embossed figures, such as one pressed into a tin lid, must be three times that height: 6 mm.

The tolerance is not a target. Under regulation 4.38 a lot fails if the sample's weighted average is below the nominal quantity, if too many packs fall below nominal minus the tolerable deficiency (a "T1 error"), or if any falls below nominal minus twice it ("T2"). Fill to the declared weight on a scale able to weigh it, as worked out in weighing and calibration.

The name and address

Regulation 4.7 requires "the name and address of the person who packed the product or on whose behalf it was packed", at "a place in Australia where a document may be served personally". Its note is blunt: "A post office box address is not a place where a document may be served personally." Regulation 4.8(1)(d) exempts "imported prepackaged products" from the address rule, not the net quantity rule.

Warnings from the Poisons Standard

The cosmetics standard requires no warnings on a balm. They arrive only if a substance is scheduled at the level used, under the Therapeutic Goods (Poisons Standard, October 2026) Instrument 2026. Its reader's guide calls scheduling "recommendations to Australian States and Territories", implemented "through relevant State and Territory legislation". Schedule 5 is headed "Caution", for "a low potential for causing harm"; Schedule 6 "Poisons", for "a moderate potential". A preparation under an entry's cut-off is not caught by it.

Balm-relevant entries in the Poisons Standard (October 2026), with the level at which a non-therapeutic preparation such as a balm stays unscheduled. Read from Schedules 5 and 6 and Appendix B; the bottle exceptions for pure essential oils with restricted flow inserts are left out.
SubstanceUnscheduled in a balm up toAbove that
Camphor12.5% camphor in a solid or semi-solid preparation (2.5% in a liquid)Schedule 6
Methyl salicylate (wintergreen, sweet birch)5% methyl salicylateSchedule 5 to 25%, Schedule 6 above
Eucalyptus oil25% eucalyptus oil in the preparationSchedule 6
Clove oil, cinnamon leaf oil25% of either oil in the preparationSchedule 6
Cinnamon bark oil2% cinnamon bark oilSchedule 5
Cassia oil2%, or 5% in a dermal rubefacientSchedule 5
Pennyroyal oil4% D-pulegone in the preparationSchedule 6
Citral (3,7-dimethyl-2,6-octadienal)5% in a cosmeticSchedule 5
Lavender oil, peppermint oilAppendix B: not scheduledNot scheduled

For most balms the first column settles it. A chest rub at 5% camphor and 2% eucalyptus is under both lines, and the US camphor range of "above 3 percent up to 11 percent" quoted in the chest rub balm formula sits inside Australia's 12.5%. Camphor and menthol limits elsewhere are in menthol, camphor and actives.

Two rows catch balm makers. Wintergreen and sweet birch oils are 85 to 99% methyl salicylate, so the 5% line falls at about 5.1 to 5.9% of the oil; a strong muscle rub can cross it. Cinnamon bark and cassia oils go to Schedule 5 above 2%, reachable in a cinnamon lip plumping balm. Ordinary scenting at 0.5 to 3% is far below every line; which oils carry what is in essential oils in balms.

A scheduled balm must meet the Poisons Standard's labelling and container provisions as each state and territory applies them, far more than a warning line, so the practical answer is to stay under the cut-off.

Using a foreign label in Australia

Australia has no clause accepting foreign labels, unlike New Zealand's clause 1(11), which accepts an Australian label. The useful question is what each one lacks.

What a label built for another market usually needs before a balm is sold in Australia. Home market rules are summarised from Trebalm's pages for each jurisdiction.
ElementEU or UK labelUS labelCanadian label
Ingredient orderCheck anything at exactly 1% is in the ordered partSame checkMove anything at exactly 1% into the ordered part
NamesINCI acceptedINCI or English acceptedINCI accepted
Allergen namesMay stayNone neededMay stay
Net quantity, 15 g and overGrams accepted; check position and the 2 mm clear spaceKeep the gram figure; read reg. 4.29 before reusing the ounce figureGrams accepted
Name and addressNot needed if imported prepacked; otherwise an Australian street addressSameSame

The EU elements are in EU cosmetic labelling, the British ones in UK cosmetic labelling and the US label in US cosmetic labelling. Going the other way, New Zealand accepts an Australian list but still wants a batch code and local contact details.

What this page cannot settle

Three judgements stay with you: whether your list is "prominently shown" and "clearly legible" on your container; whether anything short of a physical display or leaflet would satisfy section 7(3); and how your state applies the Poisons Standard to a scheduled product. The wider Australian Consumer Law on claims such as "natural" is a separate regime.

The mechanics settle cleanly. Write the list to section 7(2) in English or INCI names, put grams and a street address on anything of 15 g or more, and check the actives against the poisons table before you scale up.

Frequently asked questions

What must be on a cosmetic label in Australia?

Every cosmetic needs an ingredient list under the Consumer Goods (Cosmetics) Information Standard 2020: ingredients at 1% or more in descending order by volume or mass, then those under 1% in any order, then colour additives, in English or INCI names, prominently shown and clearly legible. Packs of 15 g or more also need a net quantity in grams and the packer's Australian address under the National Trade Measurement Regulations 2009.

Does a lip balm in Australia need a net weight on the label?

Not if it weighs less than 15 g. Schedule 4, item 5.3 of the National Trade Measurement Regulations 2009 exempts articles packed in a quantity under 15 g or 15 mL from both the measurement marking and the name and address rules, unless they are therapeutic goods. If you print the weight anyway, regulation 4.4(3) says the marking must then comply with the usual size and placement rules.

Do Australian cosmetic labels have to use INCI names?

No. Section 8(2) of the information standard allows either English names or International Nomenclature Cosmetic Ingredient names, so "Beeswax" and "Cera Alba" are both lawful. INCI is still worth using if the same label will go to Canada or the EU, where it is compulsory, or to New Zealand.

Can I just write "fragrance" on an Australian cosmetic label?

Yes. Section 7(8) lets a fragrance be shown by the word "fragrance", "fragrances", "parfum" or "parfums", and section 7(7) allows "flavour" or "aroma" for a flavour. Australia does not require fragrance allergens to be named individually, unlike Canada and the EU, though listing them is allowed and lets one label serve several markets.

Does a camphor balm need a poisons warning in Australia?

Only above 12.5% camphor. The Poisons Standard (October 2026) places camphor in Schedule 6 except in solid or semi-solid preparations containing 12.5% or less, and in liquids at 2.5% or less. A chest rub at typical camphor levels is unscheduled. Methyl salicylate above 5% and cinnamon bark or cassia oil above 2% are the more common lines for balm makers to cross.

Do Australian cosmetics need a batch code or expiry date?

No. None of the information standard, the trade measurement regulations or the Poisons Standard requires a batch code or a best before date on an ordinary cosmetic balm. A batch code is still good practice, because without one a complaint cannot be traced to a production run, and New Zealand and the EU do require one.

Sources and further reading

  1. Commonwealth of Australia, Consumer Goods (Cosmetics) Information Standard 2020, F2020L01469, made 19 November 2020 under s. 134(1) of the Australian Consumer Law, registered 24 November 2020; single version, compilation 0, current at October 2026. Sections 5 to 12.
  2. Commonwealth of Australia, Explanatory Statement, Consumer Goods (Cosmetics) Information Standard 2020, registered 24 November 2020, including Attachment A.
  3. Commonwealth of Australia, National Trade Measurement Regulations 2009, compilation 8 (F2024C00311), compilation date 20 March 2024. Regulations 4.1 to 4.14, 4.29, 4.36 and 4.38, Schedules 4 to 6.
  4. Commonwealth of Australia, Therapeutic Goods (Poisons Standard, October 2026) Instrument 2026, F2026L01327, registered 30 September 2026. Reader's guide, Schedules 5 and 6, Appendix B.

Reviewed and updated 25 October 2026. Spotted an error? Tell us and we will fix and log it.