Buyer questions · Purchase decisions
Export of cosmetics to the EU: What do the CPSR, the Responsible Person and CPNP require?
The EU relies on self-certification and notification: a qualified assessor issues the CPSR (Annex I of 1223/2009), and then an EU-based Responsible Person notifies the product in CPNP. Every ingredient is checked against CosIng (36,023 entries) and Annexes II–VI before the CPSR, not after.
1Step 1: run every ingredient through the annexes
Annex II (prohibited), III (restricted), IV (colorants), V (preservatives), VI (UV filters), amended annually; work from the consolidated text. The on-site CosIng search covers 36,023 entries with function, annex and limit.
2Step 2: CPSR and the PIF
A qualified safety assessor signs the CPSR based on the Product Information File: formula, raw-material specs and COAs, stability and preservative-challenge data, microbiology, packaging compatibility and label artwork. The PIF is kept for 10 years.
3Step 3: the Responsible Person and CPNP
The RP must be an EU legal entity named on the label; once notified in CPNP the product can be placed on the market without waiting for approval. The factory provides the technical dossier and ISO 22716 evidence; it cannot stand in for the RP.
Follow-up questions
- Q:How long does a CPSR take?
- A:The assessment itself takes weeks if the file is complete; the main bottleneck is the stability and challenge-test data: accelerated stability alone takes 3 months.
- Q:Does the same file cover the UK?
- A:Not as-is: the UK uses its own Cosmetics Regulation and SCPN notification with a UK-based RP; most of the technical file can be reused, but the notification and RP cannot.
Figures sourced from:欧盟 CosIng 检索各国备案索引质检体系
Updated 2026-09-16
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