Sell cosmetics in Europe CPNP: responsible person and labelling requirements must be completed before a cosmetic product is placed on the EU market. You need an EU-established responsible person, a Product Information File, a cosmetic product safety assessment, a CPNP notification and labels adapted to each country of sale. These rules also apply to online sales and marketplaces.
Key takeaways
- A cosmetic product may only be placed on the EU market when an EU-established responsible person has been designated.
- Notification through the Cosmetic Products Notification Portal (CPNP) must happen before placing the product on the market, but it is not an approval or confirmation of compliance.
- The Product Information File (PIF) must be kept by the responsible person for ten years after the last batch of the product was placed on the market.
- Labels must identify the responsible person, batch, ingredients and information needed for safe use in the languages required by each Member State.
- A marketplace, FBA warehouse or private-label supplier does not transfer your regulatory obligations to another party.
Which sellers and products are covered?
Any operator making a cosmetic available in the European Union is covered, including sellers operating only online. Classification depends on the product's intended use, presentation, formula and claims.
The main text is Regulation (EC) No 1223/2009 on cosmetic products. It covers products intended to be placed in contact with the external parts of the human body, teeth or oral mucous membranes, mainly to clean, perfume, change appearance, protect, keep in good condition or correct body odours.
A face cream, shampoo, perfume, deodorant, lipstick or serum may fall within this framework. However, a product presented as treating, preventing or curing a disease may no longer be a straightforward cosmetic. Products with a disinfecting function, medical devices and certain hybrid products also need careful classification before launch.
Your roles may overlap
The manufacturer makes the product, or has it made, and markets it under its own name or trade mark. The importer brings a product from a third country into the EU. A distributor then makes the product available further down the commercial chain.
If you buy a private-label formula, apply your own brand and import the bottles from China, you may be manufacturer, importer and seller at the same time. Your contract with the factory does not remove the responsibilities set by the Regulation.
Example: a South Korean manufacturer sends face masks to an Amazon FBA warehouse in Germany. Amazon stores and dispatches the units, but it does not create the PIF, carry out the safety assessment or automatically become the cosmetic responsible person. Before ordering, use Country Compliance to organise the checks needed for the country of origin, storage country and destination markets.
Watch claims that can change classification
The formula is not the only element authorities may consider. Advertising that promises to “cure acne”, “treat eczema” or “eliminate an infection” can raise questions about classification and substantiation, even if the product is sold as a serum or cream.
In practice, write marketing claims from the evidence held in your product file. A claim about comfort, hydration or improving appearance should not become a therapeutic claim in an Amazon listing, advertisement or unchecked translation.
Who must be the responsible person when you sell cosmetics in Europe CPNP: responsible person and labelling?
Every cosmetic placed on the EU market must have a responsible person established in the European Union. Their name or company name and address must appear on the container and packaging so that authorities can identify the party accountable for the product.
Regulation (EC) No 1223/2009 on cosmetic products establishes this cosmetics-specific role. The responsible person must, among other things, ensure compliance before market placement, keep the PIF available, arrange CPNP notification and cooperate with competent authorities.
| Situation | Possible responsible person | Key point |
|---|---|---|
| EU-established manufacturer | The manufacturer | It must hold and maintain the PIF. |
| Product imported from a third country | The EU-established importer | It may designate another person by written mandate. |
| Non-EU manufacturer with an EU partner | An EU-established person designated by written mandate | The mandate and genuine access to documents must be arranged. |
This role is not simply providing an address
The responsible person must be able to answer an authority request and provide the file for the product actually sold. It must therefore be able to connect batches, formula, label, safety report, claim evidence and CPNP information.
A registered address without a mandate, access to the PIF or a response process does not make a launch compliant. During market-surveillance checks, inaccessible documents can lead to a request for correction, suspension of sales or measures affecting the product. The broader framework for cooperation and surveillance is set out in Regulation (EU) 2019/1020 on market surveillance and compliance of products.
The cosmetic responsible person is not the GPSR responsible person
This distinction matters. The responsible person under the Cosmetics Regulation is a sector-specific function under Regulation (EC) No 1223/2009. A GPSR responsible person is an economic operator under Regulation (EU) 2023/988 for relevant consumer products; that service does not replace the responsible person required for cosmetics.
The same corporate group may sometimes organise more than one regulatory role, but you must check the applicable framework, appointed entity, mandate and documents separately. A SaaS subscription does not automatically appoint a representative.
EU Seller Kit — Before a first shipment or a multi-country launch, the EU Market Entry Compliance Assessment helps you map the checks to consider for the product, import process, VAT, packaging and economic-operator roles.
What documents must you prepare before CPNP notification?
Before notification, you need a complete Product Information File and a safety assessment appropriate to the finished cosmetic. The CPNP does not replace either of them.
The PIF must be kept readily accessible at the responsible person's address. It must be retained for ten years from the date on which the last batch was placed on the market. The Cosmetics Regulation requires, among other things, a product description, cosmetic product safety report, manufacturing method and statement of compliance with good manufacturing practice, evidence supporting claimed effects where justified, and data on animal testing where relevant.
The safety report must cover the product you actually sell
The cosmetic product safety report must be prepared by a person with the qualifications required under the Regulation. It considers matters including composition, physico-chemical characteristics, stability, microbiological quality, impurities, exposure and the toxicological profile of substances.
An ingredient safety data sheet, certificate of analysis or general supplier statement may support the file. They do not automatically replace a safety assessment for the finished product. This is often missed with private-label catalogues: the supplier may have a file for a particular formula, without that file covering your packaging, label, markets or commercial claims.
Before paying a deposit, centralise the factory's identity, bank details, formula documents, claimed certificates and batch information. Supplier Check helps you structure this information and identify inconsistencies to review before placing an order.
Claims must be capable of substantiation
Wording such as “moisturising”, “protects”, “dermatologically tested” or “reduces the appearance of blemishes” must match the product and be supported where the nature of the claim requires it. Keep the studies, tests, protocols and other evidence used to justify claims within the PIF.
Do not copy a competitor's or manufacturer's promises automatically. Two apparently similar serums may have different formulas, concentrations or directions for use. Evidence for one does not necessarily support the other's claim.
Documentation checklist before production
- The product has been assessed as a cosmetic by reference to its formula, intended use, presentation and claims.
- An EU-established responsible person has been identified and has organised access to the PIF.
- The safety report covers the formula, intended use, target users and packaging of the finished product.
- The PIF includes the required elements, including relevant claim evidence and manufacturing information.
- Batch references allow every unit sold to be linked to its supporting documentation.
- Marketing copy, instructions and product listings do not go beyond substantiated claims.
- Language versions and label artwork have been reviewed before printing.
How do you notify a cosmetic product through the CPNP?
A CPNP notification is an electronic declaration made before a cosmetic product is placed on the EU market. It is submitted by the responsible person, or by a party authorised to act on its behalf, before the product is made available for sale.
The Cosmetic Products Notification Portal provides information to competent authorities and poison centres, including for use in an incident. It does not issue permission to sell, certify product safety or validate your label. A CPNP reference is therefore not an “EU certificate”.
Follow this practical sequence
- Confirm product classification and designate the EU-established responsible person.
- Complete the PIF and safety report for the formula and use that will actually be marketed.
- Prepare the label, warnings, batch references and required language versions.
- Gather notification data: category, trade name, responsible person's details, country of origin for imported products, emergency contact, required formula information and nanomaterial data where applicable.
- Submit the CPNP notification before the product is first made available.
- Keep notification evidence with the PIF and update the arrangement if the formula, name, label, responsible person or contact details change.
Imagine that you keep the same cream name but replace a preservative or increase the concentration of an active ingredient. Do not treat that as a simple marketing variation. First have its effect on the safety assessment, PIF, label and notified information reviewed.
If you sell through Amazon, eBay, Etsy, Shopify or your own shop, check displayed information before publication as well. The Marketplace Product Compliance Scanner reviews a listing and flags traceability and compliance information to verify; it does not replace the PIF or CPNP notification.
What must cosmetic labelling include?
A cosmetic label must identify the product, its responsible person and conditions for safe use. The applicable requirements are set out in Regulation (EC) No 1223/2009 on cosmetic products, including requirements for information on the container and packaging.
Depending on the product and format, provide in particular:
- the name or company name and address of the EU-established responsible person;
- nominal content at the time of packaging;
- the date of minimum durability where required, or the period after opening where applicable;
- particular precautions for use and necessary warnings;
- a batch number or reference enabling identification;
- the product function, unless it is clear from its presentation;
- the ingredient list, normally introduced by “Ingredients” and expressed using INCI nomenclature.
Languages depend on where you sell
Consumer information must be available in the language or languages required by the Member State where the product is made available. The ingredient list follows INCI conventions, but precautions, function, quantity and other consumer-facing information must be adapted for the target market.
Example: you ship cream from Shenzhen to Germany, then activate sales in France and Spain. An English-only label may be insufficient. Prepare translations before printing, or check whether a supplementary label, carton or leaflet can be used under the rules applicable to the product and country concerned.
A common mistake is putting warnings only in the online description. A product listing can supplement commercial information, but it does not replace information required on the container or packaging. For distance-selling information under the GPSR, see the online product listing requirements, while keeping that framework separate from cosmetics-specific obligations.
How can you import and sell online without delaying launch?
Cosmetics compliance must be ready before the first market placement, but importing adds separate customs and tax formalities. A correctly notified product can still be held if its customs declaration, commercial invoice or importer identification is inconsistent.
An EORI number identifies operators for EU customs formalities. The European Commission explains its role in import and export operations on its EORI information page. If you need to apply, the EORI file preparation service helps prepare the application file; it is a one-time service unless included in a plan quota, and the number itself is issued by the competent customs authority.
Prepare customs and VAT data in parallel
Tariff classification helps determine applicable customs measures. You can generate candidate subheadings with the HS classification assistant, then confirm them through the European Commission's TARIC consultation. Do not rely only on the code shown on a supplier invoice: check that the description, composition and goods actually shipped match.
VAT depends on the sales model, import country, storage location and consumer destinations, among other factors. The EU VAT calculator helps compare common domestic, intra-EU and import VAT scenarios. For distance sales and one-stop-shop schemes, also consult the European Commission's information on OSS and IOSS.
If you send stock to a German FBA warehouse, plan for the consequences of local storage before shipment. The guide to importing stock into the EU: EORI, customs and VAT explains the steps to coordinate with your product-compliance documentation.
EU Seller Kit — For a launch involving imports, the most relevant tools are EORI file preparation, the EU VAT calculator and the Marketplace Product Compliance Scanner, each supporting a different stage of the flow.
What mistakes cause listing blocks or authority requests?
Problems often arise because the product being sold, the documents held and the information displayed do not match. Compliance needs to remain consistent from factory to product listing.
Confusing notification with compliance
A CPNP notification does not prove that the formula has been assessed or that the label is correct. It also does not prevent an authority from requesting the file. Keep a usable PIF and make sure the responsible person can provide it.
Reusing a file for a different formula or brand
Changing a fragrance, preservative, concentration, packaging or commercial claim may require the safety report and PIF to be reviewed. Equally, a file prepared for the supplier's brand does not automatically cover your own private-label brand.
Printing too early
Starting labels before finalising the responsible person, sales languages and warnings is a common source of delay. Correcting labels after thousands of units have arrived may require relabelling or prevent a listing from being published until the issue is corrected.
Forgetting obligations outside the Cosmetics Regulation
The Cosmetics Regulation does not remove customs, VAT or packaging responsibilities. Packaging may create national extended producer responsibility obligations, alongside the evolving EU framework under Regulation (EU) 2025/40 on packaging and packaging waste. For sales in France, Germany or Spain, see the guide to packaging EPR for marketplace sellers.
Which special cases should you check before selling?
Hybrid products, formula variants and sales outside the EU need separate assessment. Do not assume that one file or notification automatically covers every format, destination or commercial version.
Private label, repackaging and gift sets
For private-label products, establish who holds the existing PIF, who is designated as responsible person and whether the safety assessment covers your exact product version. If you change the brand, presentation, packaging, target market or chain of responsibility, have the scope of the documents checked before production.
Repackaging and gift sets also make traceability more difficult. Each cosmetic must remain identifiable with its precautions, ingredient list and batch. Adding an electrical device, battery or connected accessory can bring the set within other sector-specific rules.
Nanomaterials and particular substances
Nanomaterials are subject to specific requirements under the Cosmetics Regulation, including a separate prior notification in certain cases. A supplier's marketing statement is not enough: request detailed technical documentation and have classification assessed by competent professionals.
Selling in Great Britain
Great Britain is not part of the EU market. An arrangement prepared for the EU, including CPNP notification, should not be assumed sufficient for that market. If you ship to or through Great Britain, assess customs formalities and identification separately using the guide on EU and GB EORI numbers.
Tools and services to take action
- EU Market Entry Compliance Assessment — use it before a first launch to structure checks around your products, storage countries, customs flows, VAT and compliance obligations to assess.
- Supplier Check — centralise factory identity, payment data, delivery information and claimed documents before ordering cosmetic production.
- Marketplace Product Compliance Scanner — review an Amazon, eBay, Etsy, Shopify or other marketplace listing before publication to identify compliance and traceability information to check.
- EORI file preparation — use this service when you need to prepare an EORI application for customs formalities; the competent authority issues the number.
- EU Seller Kit pricing and plans — review SaaS plans and add-on services relevant to your organisation without assuming a price, processing time or outcome.
Frequently asked questions
Is CPNP approval to sell cosmetics?
No. CPNP is a prior notification, not an authorisation, certification or validation by the European Commission. Before market placement, the product still needs an EU-established responsible person, a PIF and an appropriate safety assessment.
Can I sell Chinese cosmetics on Amazon Europe without an EU company?
A non-EU manufacturer or seller can sell in the EU, but every product needs an EU-established responsible person and must meet the applicable cosmetics requirements. Import arrangements, EORI, VAT, packaging obligations and marketplace requirements must be organised separately.
Is the cosmetic responsible person the same as the GPSR responsible person?
Not necessarily. The cosmetic responsible person is governed by Regulation (EC) No 1223/2009, whereas the GPSR responsible person is governed by Regulation (EU) 2023/988 for relevant consumer products. Check the role, mandate, appointed entity and documents required under each applicable framework.
Can I use an English-only label throughout the European Union?
Generally, no. Consumer-facing information must be provided in the language or languages required by the Member State where the cosmetic is sold. INCI conventions apply to the ingredient list, but precautions, function and other consumer information must suit the target market.
Do I need a separate PIF for every fragrance or variant?
It depends on the formula, composition, packaging and how variants are documented in the safety assessment. A change in fragrance, concentration, preservative or presentation may require an update or separate assessment, so have the point reviewed by the appropriately qualified person.
Does a marketplace check my Product Information File?
A platform may request documents or block a listing, but its review does not replace your regulatory obligations. Authorities can request the PIF from the responsible person regardless of whether a marketplace accepted the listing.
Can I sell the same cosmetic in the EU and Great Britain using the same file?
EU and Great Britain requirements must be assessed separately. Do not assume that an EU CPNP notification, EU responsible person or EU-focused label is sufficient for Great Britain; check local rules and customs flows before shipping.
Official sources
- Regulation (EC) No 1223/2009 — cosmetic products — sets the requirements for the responsible person, PIF, safety assessment, CPNP notification and cosmetic labelling.
- Regulation (EU) 2019/1020 — market surveillance and compliance of products — sets out the market-surveillance framework and expected cooperation by economic operators.
- European Commission — Economic Operators Registration and Identification (EORI) — explains operator identification for EU customs formalities.
- European Commission — TARIC consultation — allows you to consult tariff classifications and customs measures applying to goods.
- European Commission — VAT One Stop Shop (OSS / IOSS) — explains VAT one-stop-shop arrangements for certain cross-border sales models.
- Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation — sets the EU packaging framework to consider alongside national EPR requirements.
This content provides general information and is not legal advice.