What are the cosmetic labelling requirements in New Zealand?
The Cosmetic Products Group Standard label clause by clause, which balms it now reaches, what a foreign label still lacks, and the 31 December 2026 stock deadline.
New Zealand sets cosmetic labelling in the Cosmetic Products Group Standard 2020 (HSR002552), issued by the Environmental Protection Authority under the Hazardous Substances and New Organisms Act 1996. A covered product needs an ingredient list, a batch code and New Zealand contact details, and an Australian, US, Canadian, UK or EU compliant label can replace only the first. Since 1 January 2026 the standard also covers non-hazardous cosmetics with a hazardous ingredient, such as a balm scented with a classified fragrance, and stock made to the old rules can be sold only until 31 December 2026.
List ingredients at 1% or more in descending order, then those under 1% in any order, then colour additives. Fragrance may read "fragrance" or "parfum". Add a batch code and NZ contact details. An AU, US, CA, UK or EU compliant label replaces the list rules but not those two. Pre-2026 stock must be sold by 31 December 2026 and disposed of by 30 June 2027.
Trebalm is a reference site, not a law firm, and this page is orientation for a small maker rather than legal advice. It covers the Group Standard and the labelling notice it points to, not the rest of New Zealand consumer law. The EPA's own copy of the standard could not be fetched for this page, so the consolidated text quoted here is a published mirror of the January 2024 version, checked against both Gazette notices. Last checked 23 October 2026.
Which cosmetics the Group Standard covers
The Group Standard treats cosmetics as hazardous substances under the HSNO Act, approved as a group: a single approval covers every product that meets its scope and conditions, and the maker or importer assigns each product to it rather than applying product by product. It came into force on 30 April 2021. Its explanatory note lists "lip balm" by name among typical products, alongside lipsticks and lip liners, though it adds that being on the list does not mean a product is hazardous.
That last point is the whole story of the 2026 change. Until the end of 2025, the standard only applied to a cosmetic that itself classified as hazardous under the Hazardous Substances (Hazard Classification) Notice 2020. A lip balm that did not classify was simply outside it, with no Group Standard label rules at all. The Cosmetic Products Group Standard (Amendment) Notice 2024, dated 25 January 2024, replaced the scope clause with two limbs. From 1 January 2026 the standard applies to:
- any cosmetic that classifies as hazardous (clause 4(2)(a)); and
- "any cosmetic product that does not classify as hazardous but contains a component that classifies as hazardous" (clause 4(2)(b)).
The second limb is what reaches the balm trade. The test is now per ingredient, not per finished product. A balm at 1% of a fragrance oil may never reach the concentration at which the finished product classifies, but if the fragrance oil is classified, the balm is in scope.
Checking your own formula in five minutes
Open the safety data sheet for every raw material and read section 2. A supplier's EU sheet for a lavender fragrance (French Color & Fragrance, Lavender #EU24194F, revised July 2020) classifies the mixture as skin sensitisation Category 1 (H317), aspiration hazard Category 1 (H304), eye irritation Category 2 (H319) and chronic aquatic hazard Category 2 (H411). Its section 3 lists lavandin oil at 7.5 to 15% and linalyl acetate at 1 to 2%, both classified skin sensitisation Category 1. Every one of those four classifications appears by name in the list in clause 4(4) of the Group Standard, so a balm scented with that fragrance, at any dose, is in scope from 1 January 2026.
| Your product | Up to 31 December 2025 | From 1 January 2026 |
|---|---|---|
| Finished product classifies as hazardous | In scope, full conditions | In scope, full conditions |
| Product does not classify, but an ingredient does (a fragrance or essential oil with an H317 on its sheet, for example) | Outside the standard | In scope: ingredient list, batch code, contact details, and the ingredient schedules |
| No ingredient classifies (no hazard classification in section 2 of any raw material sheet) | Outside the standard | Still outside the standard |
| Contains a substance in Schedule 4, or breaks a Schedule 5 to 8 limit | Excluded | Excluded: cannot be supplied under the standard |
| Registered medicine, or a product that needs registration under the Medicines Act 1981 | Not covered | Not covered |
Read the sheet you were actually sent, not a generic one. The bottom row is a claim boundary, not a formula one: a balm that says it treats eczema is heading towards the Medicines Act rather than the Group Standard, which is the same trap described in cosmetic versus drug claims.
The standard also hands you a paperwork duty. Clause 10 makes the importer or manufacturer responsible for deciding that a product falls under this standard, and requires a record of how that was decided, detailed enough "to allow for independent verification" and available for inspection. For a small maker that is a page per formula: raw materials, the section 2 classification of each, and the conclusion. It belongs in the same folder as your batch records.
What a New Zealand label must carry
The label conditions sit in clause 1 of Schedule 1. Condition 1(1) first imports "the relevant provisions" of the Hazardous Substances (Labelling) Notice 2017, and the Amendment Notice added an advisory note that settles what that means for the newly covered products: for a non-hazardous cosmetic with a hazardous component, the relevant provision is clause 12(1) of the Labelling Notice and nothing else. So a fragranced balm that does not itself classify needs no GHS pictograms, signal words or hazard statements. A cosmetic that does classify takes the full notice.
| Element | Source | The rule | Replaced by an AU, US, CA, UK or EU label? |
|---|---|---|---|
| Ingredient list | Schedule 1, clause 1(2) | 1% or more in descending order by volume or mass, then under 1% in any order, then colour additives in any order. Flavour and fragrance by a collective word or by their ingredients | Yes |
| Label conditions from Schedules 5 to 8 | Clause 1(4) | Any warning or condition printed against a restricted ingredient, colourant, preservative or UV filter you use | Yes |
| Batch or source code | Clause 1(3) | "The manufacturer's original source or batch code information" | No |
| Contact details | Labelling Notice clause 12(1) | Enough to contact the New Zealand importer or manufacturer in person or by telephone | No |
| "(nano)" after nanomaterials | Clause 1(10) | Every nanomaterial ingredient followed by the word nano in brackets | No |
| Free samples and testers | Clause 1(12) | The whole labelling condition does not apply | Not needed |
The Group Standard itself has no net quantity rule (other legislation may), no durability date or period after opening, and no responsible person in the European sense. The contact detail is the nearest equivalent: a way to reach someone in New Zealand, by phone or in person. The Labelling Notice allows the overseas supplier's details instead of the importer's only where the product goes straight into a workplace for use, or is imported by an individual for personal use. Neither describes a balm imported for sale.
The batch code row is the one that catches makers who sell into New Zealand from the United States. Federal US cosmetic rules do not require a batch code, as the US labelling page sets out, so a fully compliant US tube can lack the one element New Zealand insists on whichever route you take. European and UK labels already carry one under Article 19(1)(e), as covered in EU cosmetic labelling.
The ingredient list, clause 1(2), line by line
The order is fixed in five steps. First, every ingredient at 1% or more, colour additives excepted, in descending order "by volume or mass". Second, ingredients under 1%, in any order. Third, colour additives, in any order. Fourth, flavour, written as "flavour", "flavours", "aroma" or "aromas", or as the ingredients of the flavour. Fifth, fragrance, written as "fragrance", "fragrances", "parfum" or "parfums", or as its ingredients. Names may be the common chemical name or the INCI name (clause 1(9)), which is more relaxed than the EU, where the names must come from the Article 33 glossary.
- "By volume or mass" is a choice, not a licence to switch. For a balm, weigh: oils and waxes differ in density, so ordering by volume can put a 20% wax ahead of a 22% oil. Pick mass and keep to it.
- The collective word is allowed, and the EU allergen names are not demanded. "Parfum" alone satisfies clause 1(2)(e). Nothing in the New Zealand text requires the individual allergens the EU requires above 0.001% in leave-on products. The EU thresholds and their dates are on the fragrance allergen labelling page.
- Essential oils are fragrance. The Group Standard's definition of a fragrance ingredient expressly includes "essential oils, natural extracts, distillates and isolates", so lavender oil in a lip balm can be declared as "fragrance". Naming the oil helps buyers with an essential oil allergy: see essential oils in balms.
Worked on a 4.25 g lip balm at castor oil 40%, beeswax 25%, shea butter 20%, jojoba 13.5%, lavender oil 1%, tocopherol 0.5%, a New Zealand list could read: "Ingredients: Ricinus Communis (Castor) Seed Oil, Cera Alba, Butyrospermum Parkii (Shea) Butter, Simmondsia Chinensis (Jojoba) Seed Oil, Lavandula Angustifolia (Lavender) Oil, Tocopherol". Lavender at exactly 1% stays in the ordered part of the list. What may be left out is narrow: impurities in raw materials, processing aids absent from the finished product, and solvents or carriers used in "strictly necessary quantities" for a fragrance. How buyers read the result is the subject of reading a balm label.
Clause 1(10) requires "(nano)" after every nanomaterial in the list, meaning an insoluble or biopersistent, intentionally made material with a dimension or internal structure from 1 to 100 nm. Separately, clause 6 requires you to notify the EPA in writing when you first import or make a cosmetic containing nanomaterials, but that notice does not apply to nanomaterials used as colourants, preservatives or UV filters. The 2024 amendment deleted the old carve-out for zinc oxide and titanium dioxide, so what counts is what the particle does in your product. Particle size for zinc is on the zinc oxide page.
Where the list may go: carton, insert, leaflet and the 80 cm2 rule
Clause 1(7) gives four places the ingredient list may appear: on the product label; on the outer container or carton, if the product is in a primary pack; on a package insert or leaflet, "if the package is too small to include the details on the label"; or on "a leaflet at the point of sale". The fourth carries no size condition. The text does not mention online sales, so whether a product page counts as a point of sale is not settled here.
Clause 1(8) adds a display rule. Products sold from "tightly compartmentalised trays or racks", or from display units, may declare their ingredients on labelling attached to the display rather than on each unit, provided the total surface area of the product's packaging is under 80 cm2 and the product is not in a primary pack. The 80 cm2 is the whole outside of the container, not the label panel. For a round pack it is two ends (2 x pi x radius squared) plus the wall (pi x diameter x height).
| Container | Dimensions used | Ends | Wall | Total | Under 80 cm2? |
|---|---|---|---|---|---|
| Lip balm tube, capped | 16 mm across, 68 mm tall | 4.0 cm2 | 34.2 cm2 | 38.2 cm2 | Yes |
| Shallow 15 ml tin | 50 mm across, 15 mm tall | 39.3 cm2 | 23.6 cm2 | 62.8 cm2 | Yes |
| 30 ml tin | 58 mm across, 20 mm tall | 52.8 cm2 | 36.4 cm2 | 89.2 cm2 | No |
| 60 ml tin | 68 mm across, 25 mm tall | 72.6 cm2 | 53.4 cm2 | 126.0 cm2 | No |
So the display concession is a lip balm and small tin rule. A tube in a counter display box qualifies; a 30 ml tin of hand balm does not. The batch code and contact detail are not part of the list, so none of these concessions moves them off the pack. The container decides most of this before you design a label, the argument made in the packaging guide and in lip balm tube versus tin.
Using an Australian, US, Canadian, UK or EU label instead
Clause 1(11) is the provision most overseas makers rely on. The ingredient list requirements in clause 1(2) and the Schedule 5 to 8 label conditions in clause 1(4) "do not need to be met if the labelling is compliant with current labelling requirements for cosmetic products of Australia, the United States of America, Canada, the United Kingdom or the European Union, as if the substance were for sale or supply in those jurisdictions." A new clause 1(11A) does the same for the 24 hour emergency number in clause 12(2) of the Labelling Notice.
The United Kingdom is a 2026 addition. Before the amendment, the clause named only Australia, the USA, Canada and the European Union, so a label built only to Great Britain rules counts from 1 January 2026, not before.
Read the clause for what it leaves out. It waives subclauses (2) and (4), and in 1(11A) clause 12(2). It does not waive subclause (3), the batch code, subclause (10), the nano marking, or clause 12(1) of the Labelling Notice, the New Zealand contact. Those survive whichever label you use.
| Label built for | Batch code already required there? | Still to add for New Zealand |
|---|---|---|
| European Union | Yes, Article 19(1)(e) | New Zealand contact details |
| Great Britain | Yes, assimilated Article 19(1)(e) | New Zealand contact details. Accepted only from 1 January 2026 |
| United States | No federal requirement | A batch code, New Zealand contact details, and "(nano)" for any nanomaterial |
| Australia or Canada | Check that market's rules | New Zealand contact details at least, and a batch code if the home label has none |
The working rule for a maker selling from abroad: keep your home label, then apply a small New Zealand sticker with the importer's name and phone number and, if your home market does not require one, a batch code. "As if the substance were for sale or supply in those jurisdictions" means fully compliant there, not loosely modelled on it: a US label with an out-of-date adverse event contact is not a compliant US label, so it is not a compliant New Zealand one either. The UK rules are worked on a tube in UK cosmetic labelling.
The dates: what changed, and what ends on 31 December 2026
The Amendment Notice came into force on 1 January 2026, and it wrote a set of transitional clauses into a new Schedule 2. A second instrument, the Cosmetic Products Group Standard (Amendment) Notice 2024 Amendment 2025, made on 8 July 2025, amended the 2024 Notice before it took effect, mostly to add a homosalate phase-out. It came into force "on the close of 30 December 2025", which is where the 30 or 31 December 2025 dates in some trade summaries come from. It did not move the 2024 Notice's own commencement, which still reads 1 January 2026.
| Products | Import and manufacture allowed until | Supply allowed until | Disposal by |
|---|---|---|---|
| Complying with the pre-amendment scope and conditions | 31 December 2025 (passed) | 31 December 2026 | 30 June 2027 |
| Containing PFAS | 31 December 2026 | 31 December 2027 | 30 June 2028 |
| Containing homosalate at levels allowed before the amendment | 30 June 2027 | 30 June 2028 | 31 March 2029 |
The PFAS dates follow a new ban: entry 2 of Schedule 4, Table 2 prohibits any substance with at least one fully fluorinated methyl or methylene carbon, with narrow exclusions. PTFE, whose chain is nothing but -CF2- units, is caught by that wording. The homosalate dates follow a lower limit. The 2025 Amendment heads the clause "Phase out of products containing 15% homosalate", and the consolidated text now caps homosalate at 10%. Homosalate is a UV filter; clause 1(5) lets a primary sunscreen be labelled to the Australian Therapeutic Goods Order No. 92 instead. Sun claims on balms are covered under SPF in lip balm.
What 31 December 2026 means for stock on your shelf
Making to the old rules stopped on 31 December 2025. The live deadline, ten weeks from the date of this page, is the supply one: products that complied with the pre-amendment scope and conditions "may continue to supply" until 31 December 2026. A non-hazardous fragranced balm made in 2025 was outside the old scope, so it complied with the pre-amendment rules by default, and that clause is what lets you keep selling it unlabelled for now. On 1 January 2027 that permission ends.
Then clause 5 of Schedule 2 says that cosmetic products "that do not comply with the Post-Amendment scope and conditions must be disposed of by 30 June 2027". It attaches to non-compliance, not date of manufacture. A 2025 tube stickered with an ingredient list, batch code and New Zealand contact meets the label conditions; one whose formula breaks the 2026 schedules can only be disposed of.
| Step | Done when |
|---|---|
| 1. List every product made before 1 January 2026 still in stock or with stockists | Counts per product and per batch, including consignment stock in shops |
| 2. Decide scope for each formula | Section 2 of every raw material sheet read and the clause 10 record written |
| 3. Check the formula against the 2026 schedules | No Schedule 4 substance, no Schedule 5 to 8 limit exceeded, fragrance within IFRA limits |
| 4. Sell or relabel | In-scope stock either sold by 31 December 2026, or labelled with list, batch code and contact details |
| 5. Deal with what is left | Anything still non-compliant disposed of by 30 June 2027, and the disposal written down |
The supply clause applies to "a person", which includes a shop holding your old tubes on consignment, so tell stockists the date. If your batch records cannot tell a 2025 tube from a 2026 one, step 1 is impossible.
Beyond the label: IFRA, records and the harm clause
Four other conditions apply to anything in scope, none of them printed on the pack.
- IFRA compliance. Clause 9 requires any fragrance material made or imported under the standard to comply with the IFRA Standards, defined in Schedule 3 as "the 50th amendment". IFRA itself has moved on to the 51st Amendment, as the fragrance allergen labelling page notes, so check which amendment your certificate was written against. Reading the certificate is covered in fragrance oils in balms.
- Banned components. Schedule 4, Table 2 adds two New Zealand-only bans to the European list: methyl methacrylate and PFAS. A component banned by IFRA is excluded from the standard outright under clause 4(5)(h).
- No harm. Clause 7 says a product "must not cause damage to human health when applied under normal or reasonably foreseeable conditions of use", taking account of its presentation, its labelling and its instructions. It sets an outcome, not a document, but a short written safety rationale of the kind described in safety assessment and the CPSR is how a maker shows they met it.
- Safety data sheets. Condition 2 applies the Safety Data Sheets Notice to products in scope, but the advisory note limits a non-hazardous product with a hazardous component to clause 12(1) of the Labelling Notice, so a fragranced balm that does not classify needs no sheet of its own.
The Group Standard has no product notification. Its only filing is the nanomaterial notice in clause 6. Compare the systems in notification portals: here, the clause 10 record does the work a notification does elsewhere.
What this page cannot settle
This page covers the Group Standard and the clause of the Labelling Notice it imports, not other New Zealand law on goods. It quotes the Labelling Notice as published on 3 November 2017; the consolidated text was not reachable for this page.
Classification is the judgement the scheme rests on, and it is yours. A supplier's sheet may be written to another jurisdiction's rules, while New Zealand classifies under its own Hazard Classification Notice 2020, which wins where they differ. Whether a finished balm classifies depends on concentration thresholds this page does not set out.
An Australian or Canadian label used under clause 1(11) has to be judged against rules this site has not yet written up. Start from your own formula, work out which raw materials classify, and build the label from there.
Frequently asked questions
Do I need to list ingredients on a lip balm sold in New Zealand?
Yes, if the balm is covered by the Cosmetic Products Group Standard, which from 1 January 2026 includes any cosmetic containing an ingredient that classifies as hazardous, such as most fragrance and essential oils. The list goes in descending order for ingredients at 1% or more, then the rest in any order, then colour additives. On a small pack it may go on an insert, a point-of-sale leaflet or, under 80 cm2, a display.
Is a US or EU label enough in New Zealand?
Mostly. Clause 1(11) accepts labelling that complies with Australian, US, Canadian, UK or EU cosmetic rules in place of New Zealand's ingredient list and Schedule 5 to 8 label conditions. It does not replace the batch code, the "(nano)" marking or the New Zealand importer or manufacturer contact details, so a US label usually needs a batch code and a local contact sticker added before sale.
What happens on 31 December 2026 for cosmetics in New Zealand?
It is the last day you may supply cosmetic products that complied only with the rules in force before 1 January 2026. From 1 January 2027 everything supplied must meet the amended scope and conditions, and products that do not comply must be disposed of by 30 June 2027. PFAS products and products using homosalate at the old limit have later dates, running to 2028 and 2029.
Does an unscented balm need a New Zealand cosmetic label?
Under the Group Standard, only if one of its ingredients classifies as hazardous, or the finished product does. If no raw material safety data sheet shows a hazard classification, the product falls outside the standard's scope and its label conditions. Record how you reached that conclusion. Other New Zealand law on goods still applies, and many makers list ingredients anyway because buyers expect it.
Can I write "parfum" instead of listing essential oils?
Yes. Clause 1(2)(e) allows fragrance to be declared as "fragrance", "fragrances", "parfum" or "parfums", or by its ingredients, and the standard defines fragrance ingredients to include essential oils. Unlike the EU, New Zealand does not separately require named fragrance allergens. An EU label that names them is still acceptable, because clause 1(11) accepts EU compliant labelling.
Is a batch code required on cosmetics in New Zealand?
Yes. Clause 1(3) of Schedule 1 says the label must provide "the manufacturer's original source or batch code information", and the foreign label exemption in clause 1(11) does not waive it. Free samples and testers are the only exception, because clause 1(12) disapplies the labelling condition for them. A US label, which has no federal batch code rule, needs one added.
Sources and further reading
- Environmental Protection Authority, Cosmetic Products Group Standard 2020, HSR002552, as amended January 2024, consolidated text (mirror of the EPA publication).
- Environmental Protection Authority, Cosmetic Products Group Standard (Amendment) Notice 2024, New Zealand Gazette 2024-sl388, dated 25 January 2024, in force 1 January 2026.
- Environmental Protection Authority, Cosmetic Products Group Standard (Amendment) Notice 2024 Amendment 2025, New Zealand Gazette 2025-sl3889, made 8 July 2025, in force at the close of 30 December 2025.
- Environmental Protection Authority, Hazardous Substances (Labelling) Notice 2017, New Zealand Gazette, 3 November 2017.
- UL Solutions, New Zealand Imposes Requirements on Non-Hazardous Cosmetics, on the scope before and after the amendment.
- French Color & Fragrance, Safety Data Sheet, Lavender #EU24194F, version 1.1, revised 2 July 2020.
Reviewed and updated 23 October 2026. Spotted an error? Tell us and we will fix and log it.