EU product compliance for cosmetics and personal care brands

Cosmetics and personal care brands selling into the EU sit under more overlapping rules than almost any other consumer category. The Cosmetic Products Regulation (Regulation (EC) No 1223/2009) is the foundation, but on top of it now sit the General Product Safety Regulation, the Packaging and Packaging Waste Regulation, the EmpCo rules on environmental claims, and REACH and CLP for substances and mixtures. This guide maps what applies to what, and where brands actually get caught.

Start with the cosmetics regulation itself

Everything else layers on top of Regulation 1223/2009, so the baseline matters. For each product placed on the EU market you need a Responsible Person established in the Union, a Product Information File including a Cosmetic Product Safety Report, notification through the Cosmetic Products Notification Portal before placing on the market, labelling that meets Article 19 including the ingredient list in INCI nomenclature, and compliance with the annexes on prohibited and restricted substances.

Two points cause most trouble. The cosmetics Responsible Person is a defined role under this regulation and is not automatically the same appointment as a GPSR Responsible Person for your other product lines — although one provider often covers both, the mandates must actually say so. And a product's classification is not a marketing choice: a claim to treat a condition can move a product from cosmetic to medicinal, with an entirely different authorisation route.

Where GPSR fits

The GPSR is the general safety net, and for cosmetics it mainly bites at the edges of your catalogue: applicators, brushes, sponges, devices, gift sets containing non-cosmetic items, and packaging that presents a physical hazard such as a small detachable part reachable by a child. Those items are products in their own right, need their own technical documentation and traceability, and need an EU-established responsible operator named in the online offer.

Distance selling obligations also apply generally: your listings must carry the manufacturer's details, the EU responsible operator's details, product identification, and any warnings — visible before purchase, not only in the box.

Packaging: PPWR and EPR

Cosmetics are a packaging-heavy category, which makes the PPWR, applicable since 12 August 2026, unusually relevant.

Immediate obligations to check: a Declaration of Conformity and technical documentation for every packaging format; the 100 ppm limit on the sum of lead, cadmium, mercury and hexavalent chromium; PFAS limits where packaging is food-contact, which can catch some crossover formats; and the 40% cap on empty space in ecommerce parcels, which is a real risk for brands shipping small jars in large boxes with generous void-fill.

Then there is EPR. Packaging EPR registration remains national: Germany, France, Spain, Italy, the Netherlands and others each require registration, tonnage reporting and fees. Cosmetics brands frequently register in one market and forget that adding a second country adds a second registration. Marketplaces increasingly check.

Later PPWR waves — recyclability grades from 2028, harmonised labelling from 2028, recycled content minimums in plastics from 2030 — will shape packaging decisions you are making now. Refill formats and mono-material components are worth evaluating on that horizon rather than at the deadline.

Claims: EmpCo and the cosmetics claims rules

Personal care marketing runs on adjectives, which is exactly why this is the highest-risk area for the category. Two regimes overlap.

The cosmetics-specific common criteria for claims have long required that claims be truthful, evidenced, honest and fair. The EmpCo Directive, applying from 27 September 2026, adds a harder line on environmental claims specifically.

Banned outright under EmpCo: bare generic claims such as "eco-friendly", "green", "sustainable" or "kind to the planet" without demonstrated excellent environmental performance; whole-product superiority claims based on one attribute, such as calling a product sustainable because the cap contains recycled plastic; carbon-neutral, climate-neutral or CO2-compensated claims based on offsetting; and self-designed sustainability badges that imply third-party certification.

Also relevant to this category are "free-from" claims. Claiming a product is free from an ingredient that is prohibited anyway, or disparaging a legally permitted ingredient, has long been problematic under the cosmetics claims criteria, and the EmpCo framing on presenting legal requirements as advantages points in the same direction. "Paraben-free" and "chemical-free" are the usual examples; the latter is simply false.

The practical fix is unglamorous and cheap: replace adjectives with figures and sources. "Bottle contains 50% post-consumer recycled PET (supplier declaration, February 2026)" survives scrutiny in a way that "sustainable packaging" cannot.

Substances: REACH and CLP

REACH applies to substances and mixtures, and cosmetics brands touch it in three ways. First, substances of very high concern: if an article you supply contains an SVHC above 0.1% by weight, you have communication duties down the chain and SCIP database notification obligations. Applicators, packaging components and devices are articles. Second, if you or your fillers import raw materials into the EU above the tonnage thresholds, registration duties may sit with the importer. Third, CLP classification, labelling and packaging rules apply to products that are mixtures presenting hazards — nail products, some solvents-based removers, certain aerosols — including child-resistant fastenings and tactile warnings where required.

Where you rely on a contract manufacturer, get the substance position in writing rather than assuming it is handled. "Our filler manages that" is not evidence.

The gaps we see most often in cosmetics catalogues

Notification drift. The formulation changed, the CPNP notification did not. Any change affecting the safety assessment needs the file and the notification updated.

Labelling in the wrong languages. Warnings, function and precautions must be in the language required by each market you sell into. Selling into six countries from one English label is a common and easily detected failure.

Ingredient lists that are not INCI. Marketing names in the ingredient list, or a list ordered by narrative rather than concentration.

Accessories treated as packaging. A bamboo brush in a gift set is a product with its own documentation and traceability requirements.

One EPR registration for six markets. Almost universal in fast-growing brands.

Legacy green claims on old pages. The current product page is clean; a 2023 blog post, a PDF catalogue and an Instagram-linked landing page still say "100% eco-friendly".

Batch traceability that stops at the filler. You need to be able to identify and trace product batches yourself, including for a recall you did not initiate.

Marketplaces and the beauty category

Beauty is one of the most heavily policed categories on marketplaces, partly because the safety and claims risks are real and partly because complaint volume is high. Practically, that means the structured compliance fields matter more than your product copy. Fill in the manufacturer details, the EU responsible operator, ingredient information and warnings in the dedicated fields rather than in the description, and keep them consistent with your label artwork. A mismatch between the label photo and the listed ingredients is a routine trigger for review.

Expect enforcement to arrive as a listing suppression rather than a letter. Keeping a single source of truth per SKU — ingredients, warnings, claims, packaging data, responsible operator — is what makes reinstatement fast when it happens.

Contract manufacturing does not transfer your duties

Most brands in this category do not fill their own products. That is fine, and it does not move the obligations. If the product is sold under your name or trademark, you are the one placing it on the market, and the safety assessment, notification, labelling and claims sit with you or your appointed Responsible Person.

What that means contractually: your supply agreement should oblige the filler to provide the safety assessment inputs, formulation disclosure to the safety assessor, substance declarations, and notice of any formulation change before it ships. Without a change-notification clause, you will discover a reformulation when a customer complains — which is also when your notification becomes out of date.

A one-page record per SKU

The brands that handle this well keep one record per product containing: the Responsible Person, the Product Information File location, the CPNP notification reference and date, label artwork version and languages, the full INCI list, every claim published with its evidence reference, packaging components with materials and weights, EPR registrations by country, and any accessory included in the pack with its own documentation. Everything in this article can be answered from that page, and audits stop being projects.

A sequencing suggestion

If everything above applies at once, do it in this order: confirm the cosmetics fundamentals for each SKU (Responsible Person, Product Information File, notification, label); then sweep environmental claims, because they are the fastest to fix and the fastest to be reported; then packaging documentation and EPR registrations, which take supplier time; then substances and accessories, which need contract-manufacturer input; then the later PPWR waves as a design programme.

Educational information only, not legal advice. Cosmetics classification, safety assessment and national enforcement are specialist areas — work with a qualified safety assessor and advisor for your specific formulations and markets.