EU compliance for cosmetics sellers: what is different from GPSR

Cosmetics are a special case in EU product compliance. The Cosmetics Regulation (EC 1223/2009) is a standalone, comprehensive framework that predates GPSR and operates alongside it. Cosmetics sellers face a distinct set of requirements — including their own "Responsible Person" role that is different from the GPSR EU Responsible Person — and getting the two confused is one of the most common compliance mistakes in this category.

This guide explains the cosmetics-specific regulatory stack, how it differs from general consumer product compliance, and where the two frameworks overlap.

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The Cosmetics Regulation — the primary framework

Regulation (EC) 1223/2009 governs the safety, labelling, claims, and market access of cosmetic products in the EU. It applies to any substance or mixture intended to be placed in contact with the external parts of the human body or with the teeth and mucous membranes of the oral cavity, for the purpose of cleaning, perfuming, changing appearance, protecting, keeping in good condition, or correcting body odours.

This covers: skincare, haircare, makeup, fragrances, oral hygiene products, nail products, bath and shower products, deodorants, shaving products, sunscreen, and similar.

The Cosmetics Responsible Person

The Cosmetics Regulation has its own Responsible Person (RP) requirement — Article 4. This is NOT the same as the GPSR EU Responsible Person under Article 16 of Regulation 2023/988. The two roles have different legal bases, different duties, and different scopes.

Cosmetics RP (Regulation 1223/2009, Article 4):

• must be established in the EU;
• is responsible for ensuring the cosmetic product complies with the Cosmetics Regulation;
• must hold the Product Information File (PIF);
• must ensure the safety assessment has been carried out by a qualified assessor;
• is responsible for the notification of the product on the CPNP (Cosmetic Products Notification Portal);
• carries ongoing obligations for post-market surveillance, adverse event reporting, and compliance with ingredient restrictions.

GPSR EU RP (Regulation 2023/988, Article 16):

• is the named contact for market-surveillance authorities;
• holds technical documentation;
• cooperates with corrective actions and Safety Gate notifications;
• appears on the product, packaging, and listing.

The Cosmetics RP has more extensive duties — including ensuring the safety assessment is done and maintaining the PIF. The GPSR EU RP is primarily an administrative and liaison role. They are not interchangeable.

Do cosmetics sellers need both?

This depends on how GPSR interacts with the Cosmetics Regulation for a given product. The Cosmetics Regulation is a sector-specific regulation that covers cosmetics comprehensively. Where a product falls squarely within the Cosmetics Regulation, the GPSR requirements may be met through compliance with the sector-specific rules — but the GPSR listing information requirements (Article 19) still apply to online sales. In practice, cosmetics sellers should ensure they have a Cosmetics RP and that their online listings meet GPSR Article 19 requirements for manufacturer and responsible person information.

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Product Information File (PIF)

Every cosmetic product placed on the EU market must have a Product Information File maintained by the Responsible Person. The PIF must contain:

• a description of the cosmetic product;
• the Cosmetic Product Safety Report (CPSR), including Part A (safety information) and Part B (safety assessment by a qualified assessor);
• a description of the manufacturing method and a statement of compliance with GMP (EN ISO 22716);
• proof of the effect claimed for the product (efficacy evidence), where justified;
• data on animal testing (the EU bans animal testing for cosmetics).

The PIF must be available to the competent authority of the Member State where the file is kept, at the address of the Responsible Person, within a reasonable time following a request.

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CPNP notification

Before placing a cosmetic product on the EU market, the Responsible Person must notify it through the Cosmetic Products Notification Portal (CPNP). The notification includes the product category, the product name, the Responsible Person's identity, the country of origin, the Member State where the product will first be placed on the market, and the frame formulation or exact composition.

This notification is mandatory. Selling a cosmetic product in the EU without CPNP notification is non-compliant.

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Ingredient restrictions

The Cosmetics Regulation maintains extensive lists of restricted, prohibited, and conditionally permitted substances:

• Annex II — list of substances prohibited in cosmetic products (over 1,600 entries);
• Annex III — list of substances subject to restrictions (concentration limits, conditions of use, warnings);
• Annex IV — list of permitted colorants;
• Annex V — list of permitted preservatives;
• Annex VI — list of permitted UV filters.

Compliance requires knowing the exact formulation of every product and verifying it against these annexes. If you source finished products from a third-party manufacturer, the manufacturer should provide formulation data and confirmations of compliance.

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Labelling requirements

Cosmetic product labelling under Regulation 1223/2009 must include:

• the name or registered name and address of the Responsible Person;
• the country of origin (for imported products);
• the nominal content at the time of packaging (weight or volume);
• the date of minimum durability (or, if durability exceeds 30 months, the period-after-opening (PAO) symbol);
• particular precautions for use;
• the batch number;
• the product function (unless apparent from the presentation);
• the list of ingredients (using INCI nomenclature).

For online sales, all labelling information must be available to the consumer before purchase — consistent with GPSR Article 19.

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Claims

Cosmetic product claims are governed by Regulation (EC) 655/2013, which sets common criteria for the justification of claims. Claims must be truthful, supported by evidence, fair, and not misleading. The regulation provides specific guidance on claims about efficacy, ingredients, and comparisons.

From 27 September 2026, EmpCo adds additional restrictions on environmental claims. Cosmetics sellers using terms like "natural," "organic" (without certification), "eco," "sustainable," or "green" will need to substantiate or remove them. This is particularly relevant for the "clean beauty" and "natural cosmetics" categories.

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How cosmetics compliance differs from general products

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How Regonance helps

Regonance identifies which regulations apply to cosmetic products — including the distinction between the Cosmetics RP and the GPSR EU RP — and surfaces missing compliance fields in your product listings. The platform covers GPSR listing requirements, EmpCo green claims, PPWR packaging obligations, and cross-references with cosmetics-specific requirements.

Scan your cosmetics products → free, no account

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Compliance guidance based on published EU regulatory texts. Does not constitute legal advice. Cosmetics compliance requires specialist input — particularly the safety assessment, which must be performed by a qualified assessor.