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Exporting cosmetics to the EU: what do the CPSR, the Responsible Person and CPNP each require?

The EU runs on self-certification plus notification: a qualified assessor issues the CPSR (Annex I of 1223/2009), 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 every year; 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 on the basis of 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 with no approval wait. The factory supplies 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 is measured in weeks when the file is complete; the long pole is the stability and challenge-test data behind it: accelerated stability alone runs 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 carries over, the notification and RP do not.

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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