EU Cosmetics Regulation and GPSR: 2026 Checklist
Cosmetic products are governed first by Regulation (EC) No 1223/2009, consolidated on 18 May 2026. The General Product Safety Regulation (GPSR) does not replace that sector law. It only fills gaps: risks or duties not covered with the same objective, including the rules for online sales.
This split matters in practice. The Commission recorded 4,671 Safety Gate alerts in 2025; cosmetics were the largest category at 36%. Almost eight in ten cosmetics alerts concerned the banned fragrance BMCHA. A CPNP notification alone therefore cannot prove that your formula, label or online offer is compliant.
Does GPSR apply to cosmetic products in the EU?
GPSR applies to cosmetics as a complementary safety net, not as a second cosmetics code. The European Commission's 2025 GPSR business guidelines state that sector-specific EU rules control the risks and objectives they already cover. The GPSR's general safety requirement only applies to risks the cosmetics rules leave open. Its rules on online offers, accident reporting and electronic information still apply where relevant.
For an ordinary cosmetic, the Cosmetics Regulation remains the main route for ingredients, the safety assessment, the Product Information File (PIF), the cosmetics Responsible Person, CPNP notification, manufacturing practice, labelling and claims. Do not create a second, generic GPSR technical file for duties that regulation already covers.
Which law governs each cosmetics compliance task?
| Compliance task | Primary rule | Practical evidence |
|---|---|---|
| Cosmetic classification, formula and human-health safety | Cosmetics Regulation | Intended purpose, formula, ingredient restrictions and exposure data |
| EU cosmetics Responsible Person | Cosmetics Regulation | Identified EU person, accepted mandate where required and compliance controls |
| Safety assessment and product file | Cosmetics Regulation | Signed CPSR and complete PIF |
| Manufacturing, label and claims | Cosmetics Regulation | GMP statement, final artwork and claim substantiation |
| Pre-market notification | Cosmetics Regulation | CPNP submission record; not an approval certificate |
| Serious undesirable effects | Cosmetics Regulation | Notify the competent authority without delay and preserve the case evidence |
| Online offer, uncovered risks and general follow-up | GPSR, only where the Cosmetics Regulation does not cover it | Dated listing capture, role mapping, warnings and incident process |
Map each task to the exact product and the right law. The phrase “GPSR covers every product” is too broad because it hides the sector-law limits described in the Commission guidelines.
What is the difference between the cosmetics RP, GPSR role and CPSR assessor?
| Role | What the role does | What the role does not automatically do |
|---|---|---|
| Cosmetics Responsible Person | Ensures the cosmetic product meets the relevant duties of the Cosmetics Regulation | The role does not by itself prove that the person is qualified to sign the CPSR |
| EU economic operator under the GPSR (named in the online offer) | Supplies the identity and contact details your online offer needs and performs the duties of its own legal role | The appointment does not automatically make that entity the cosmetics Responsible Person |
| Qualified safety assessor | Performs the cosmetic safety assessment and signs the CPSR | The assessor does not automatically become the cosmetics RP or the GPSR economic operator |
The safety assessor must hold a diploma or other formal qualification awarded after a university course in pharmacy, toxicology, medicine or a similar subject, or an equivalent course recognised by a Member State. “Knowledge and experience” alone does not meet this test.
One company may take more than one role only if it meets each legal definition separately, accepts each mandate and has the required competence. The contract and the public product information should name the roles precisely.
What must a non-EU cosmetics brand prepare before EU sale?
| Step | Evidence to have before placing on the EU market | Which rule |
|---|---|---|
| 1 | Product classification and intended-purpose decision | Cosmetics Regulation |
| 2 | Final formula, specifications and ingredient restriction review | Cosmetics Regulation, including its ingredient annexes |
| 3 | EU cosmetics Responsible Person and accepted mandate where needed | Cosmetics Regulation |
| 4 | CPSR signed by a qualified safety assessor | Cosmetics Regulation (safety report rules) |
| 5 | Complete PIF accessible at the Responsible Person's address | Cosmetics Regulation; keep it for 10 years after the last batch was placed on the market |
| 6 | GMP evidence, final label and supported claims | Cosmetics Regulation |
| 7 | CPNP notification before placing the product on the market | Cosmetics Regulation |
| 8 | Final online-offer review and incident route | GPSR online-offer and follow-up duties |
The PIF has five core elements: a clear product description, the CPSR, the manufacturing method and GMP statement, proof of the claimed effect where justified, and data on animal testing by the manufacturer, its agents or suppliers. The PIF is much wider than a label pack or an ingredient list.
What must an EU cosmetics product page show?
Your online cosmetic offer should let a consumer identify the product and the relevant operators before buying. Where the GPSR's online-offer rule applies, your listing must show the manufacturer's name or trade name and postal and electronic address; where required, the EU responsible economic operator's name and contact details; a product image or other identifier; and the warnings or safety information EU law requires.
The cosmetics label itself still follows the Cosmetics Regulation. The final artwork should cover the required cosmetics RP address, nominal content, durability or period-after-opening indication, precautions, batch reference, function where not obvious and ingredients. If label information, ingredients or claims appear online, they must match the approved artwork and PIF. For example, the ingredient list on your product page must match the one on the box. The GPSR online-sales information guide gives a field-by-field listing review.
Is CPNP registration an approval or a certificate?
CPNP is a notification, not an approval. The Commission describes CPNP as a free online notification system. Once you have notified in CPNP, you need no further national cosmetics notification within the EU, but authorities can still inspect the CPSR, PIF, formula, label and market evidence.
Ordinary cosmetics also do not use CE marking or a CE-based EU Declaration of Conformity. The EU Declaration of Conformity guide explains the difference. A powered beauty device, applicator or accessory may need a separate classification and a different legal route.
Do natural or organic cosmetics follow a different EU route?
“Natural” or “organic” does not exempt a product from the Cosmetics Regulation and does not create a separate EU cosmetics approval. The formula, safety assessment, label and claims still need evidence. Claims must not suggest a property the product does not have.
Classification follows intended purpose and presentation. A cream applied to the human body for a cosmetic purpose can be a cosmetic; a beauty tool, electrical device or accessory is not automatically a cosmetic and may fall fully under the GPSR or other product legislation.
Frequently asked questions about the Cosmetics Regulation and GPSR
Does GPSR apply to cosmetic products in the EU?
Yes, but it does not replace the Cosmetics Regulation. The Cosmetics Regulation controls the cosmetic-specific duties on safety, formula, assessment, product file, notification and labelling. The GPSR only fills the gaps: uncovered risks and general duties such as the information your online offer must show.
Is a cosmetics Responsible Person the same as a GPSR Responsible Person?
No. The cosmetics Responsible Person and the EU economic operator under the GPSR are separate legal roles. One company can take both, but only if it meets and accepts the conditions of each role separately.
Is CPNP notification an EU approval or certificate?
No. CPNP is the free EU notification portal. You must notify before placing a cosmetic on the market, but the notification is not a product approval or certificate and does not replace the CPSR and PIF.
Do ordinary cosmetic products need CE marking or an EU Declaration of Conformity?
No. Ordinary cosmetics follow the Cosmetics Regulation and do not use CE marking or the CE-based EU Declaration of Conformity. A beauty device or another separately classified product may follow different legislation.
Can Grüner Baum provide cosmetics RP, PIF, CPSR and CPNP services?
Yes. Grüner Baum provides cosmetics RP, PIF, CPSR and CPNP support with its specialist cosmetics partner, plus a review of your online offer. A qualified safety assessor signs the CPSR, and the contract names the entity that accepts the cosmetics RP role. Cosmetics are scoped and quoted individually, so request an assessment for your product.
Official sources
| Topic | Legal basis | Official text |
|---|---|---|
| Definition of a cosmetic product, classification and safety | Cosmetics Regulation Article 2 and Article 3 | Regulation (EC) No 1223/2009, consolidated text of 18 May 2026 |
| Cosmetics Responsible Person | Cosmetics Regulation Article 4 and Article 5 | Regulation (EC) No 1223/2009 |
| Good manufacturing practice (GMP) | Cosmetics Regulation Article 8 | Regulation (EC) No 1223/2009 |
| Safety assessment (CPSR) and assessor qualification | Cosmetics Regulation Article 10 and Annex I | Regulation (EC) No 1223/2009 |
| Five PIF elements, access at the Responsible Person's address, 10-year retention | Cosmetics Regulation Article 11 | Regulation (EC) No 1223/2009 |
| CPNP notification before placing on the market | Cosmetics Regulation Article 13 | Regulation (EC) No 1223/2009; European Commission Cosmetic Product Notification Portal |
| Ingredient restrictions | Cosmetics Regulation Articles 14 to 17 and annexes | Regulation (EC) No 1223/2009 |
| Cosmetics label and claims | Cosmetics Regulation Article 19 and Article 20 | Regulation (EC) No 1223/2009 |
| Reporting serious undesirable effects | Cosmetics Regulation Article 23 | Regulation (EC) No 1223/2009 |
| GPSR as a complementary safety net; general safety requirement only for uncovered risks | GPSR Article 2(1); Commission Notice C/2025/6233 | GPSR text (EUR-Lex); European Commission GPSR business guidelines, C/2025/6233 |
| Online-offer information, accident reporting and electronic information | GPSR Article 19, Article 20 and Article 21 (Chapter III, Section 2) | GPSR text (EUR-Lex) |
| Cosmetics overview | European Commission | European Commission cosmetics overview |
| 2025 Safety Gate figures (4,671 alerts, 36% cosmetics, BMCHA) | European Commission 2025 Safety Gate report | European Commission 2025 Safety Gate report |
This guide was checked on 1 September 2026 and is general information, not legal advice.
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