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Cosmetics · European Union

Sell cosmetics in the European Union, ready from the first sale

Under Regulation (EC) No 1223/2009, every cosmetic needs an EU Responsible Person, a safety report (CPSR), a product file (PIF), a compliant label and a CPNP notification before it is sold. We set up the whole route, whether you export to Europe or are already there.

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Unbranded skincare products on a stone surface, with EU flags in front of a European building

One CPNP notification covers 30 European countries

Europe in numbers

A large market, and the most closely watched

The market

€110 bncosmetics retail sales in Europe in 2025Cosmetics Europe
500 mconsumers using cosmetics and personal care every dayCosmetics Europe

Market surveillance

36%of EU alerts on dangerous products in 2025 were cosmeticsEuropean Commission, Safety Gate
≈80%of cosmetics alerts concerned one banned fragrance (BMHCA)European Commission, Safety Gate

Official sources, checked on 7 November 2026.

Is this for you?

Two starting points, one EU route

The obligations are the same. What changes is who acts as Responsible Person.

Your company is outside the EU

You need a Responsible Person in the EU

  • Brands from Brazil, the US or elsewhere can only place cosmetics on the EU market through a Responsible Person established in the EU
  • Sobel acts as your Responsible Person and keeps the product file at its EU address
  • We build on your existing safety, stability and supplier data

Your company is in the EU

Your company is the Responsible Person

  • Manufacturers in the EU, importers and companies selling under their own brand are the Responsible Person
  • We prepare or review the CPSR, the product file and the label with your team
  • Support for reformulations when the annexes change

The route

Five steps before the first sale

Step 1 of 5

One company in the EU answers for your product.

Required for every product · Article 4

Talk to a specialist →

What it includes

  • Written mandate between brand and Responsible Person
  • EU name and address for the label
  • Product file kept at the RP address
  • Contact point for the authorities

Step 2 of 5

Every ingredient checked against the EU lists before any report is written.

Every formula · Annexes II to VI

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What it includes

  • Prohibited and restricted substances
  • Preservatives, colorants and UV filters on the permitted lists
  • Current CMR classifications
  • Limits, conditions and warnings for the label

Step 3 of 5

A qualified safety assessor confirms the product is safe as used.

Every product · Annex I

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What it includes

  • Part A: safety information and exposure
  • Part B: assessment and conclusion
  • Margin of safety for relevant ingredients
  • Signed by a qualified safety assessor

Step 4 of 5

The full product file, ready whenever an authority asks.

Kept for 10 years · Article 11

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What it includes

  • Product description and CPSR
  • Manufacturing method and GMP statement (ISO 22716)
  • Evidence for every claim
  • Animal testing data, where applicable

Step 5 of 5

A compliant label, then the notification before the first sale.

Before the first sale · Article 13

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What it includes

  • Label review: INCI, allergens, PAO and warnings
  • Responsible Person details on the pack
  • CPNP notification with the frame formulation
  • Language of each target country

What changes and when

EU cosmetics rules that change by 2029: formulas, labels and stock

  • Expanded fragrance allergen labelling applies to new productsRegulation (EU) 2023/1545
  • Generic environmental claims such as “eco” are banned unless proven; sustainability labels need certificationDirective (EU) 2024/825
  • 12 ingredients banned or restricted, incl. benzyl salicylate and citral: non-compliant products can no longer be placedRegulation (EU) 2026/909
  • Rinse-off products with added microplastics can no longer be placedRegulation (EU) 2023/2055
  • Non-compliant stock under Regulation 2026/909 can no longer be soldRegulation (EU) 2026/909
  • Every product on sale must carry the new allergen labellingRegulation (EU) 2023/1545
  • Leave-on products with added microplastics can no longer be placedRegulation (EU) 2023/2055
  • Shorter, staggered deadlines for newly classified CMR substances: adopted by Parliament on 22 Oct 2026, awaiting the CouncilChemicals simplification omnibus

Dates checked on 7 November 2026. We confirm each one for your products.

Coming from Brazil or the US?

What you can reuse, and what the EU needs

You already have

  • Formula and specifications
  • Supplier safety data
  • Stability and challenge tests
  • Efficacy studies
  • GMP evidence

You need for the EU

  • EU safety report (CPSR)
  • Check against EU annexes
  • EU label and address
  • CPNP notification

See what you can reuse →

Why Sobel

Regulation as a business decision, not a checklist.

Four disciplines work on every project, in the same team, from the first decision to post-market.

Strategy

Classification and market sequence decided first. The right class from day one avoids rework.

Science in house

Biological, clinical and toxicological evaluation by our own Clinical Evidence & Product Safety team.

Regulatory, five markets

ANVISA, FDA, EU MDR, MHRA and Health Canada, coordinated together.

Technology

A dedicated technology team builds the workflows that keep every project traceable and on time.

“We know how auditors think, because we’ve been one of them.”

Maik Endler

Founder & CEO

  • Mechanical engineer, trained in Germany
  • Former BSI auditor (Notified Body)
  • Industry experience at Sirona (now Dentsply Sirona)

Questions, answered

Frequently asked questions

Rules cited on this page: Regulation (EC) No 1223/2009 · Regulation (EU) No 655/2013 · Regulation (EU) 2023/1545 · Regulation (EU) 2026/909 · Regulation (EU) 2023/2055 · Directive (EU) 2024/825

Do I need a Responsible Person to sell cosmetics in the EU?

Yes. Every cosmetic placed on the EU market needs one Responsible Person established in the EU (Article 4 of Regulation (EC) No 1223/2009). For products made outside the EU, this is usually the importer or an appointed service provider. Sobel acts as Responsible Person for brands outside the EU.

What is the difference between the CPSR and the PIF?

The CPSR is the safety report, signed by a qualified safety assessor. The PIF is the full product file: it includes the CPSR, the product description, the manufacturing method with the GMP statement, and the evidence for your claims. The PIF stays at the Responsible Person’s address for 10 years after the last batch is placed on the market.

Is the CPNP notification a registration or an approval?

No. The CPNP is a free electronic notification made by the Responsible Person before the first sale. Authorities do not approve the product, but they can ask for the PIF at any time. One notification covers every EU and EEA country.

Can I use my ANVISA or FDA documents in the EU?

Partly. Formula specifications, supplier data, and stability and efficacy studies can often be reused. The CPSR, the check against the EU annexes, the label and the CPNP notification must be done for the EU.

What changes in 2026 and 2027?

The expanded fragrance allergen labelling applies to products placed on the market from 31 July 2026, and every product on sale must comply by 31 July 2028. Regulation (EU) 2026/909 bans or restricts 12 ingredients from 1 January 2027. Rules on environmental claims apply from 27 September 2026.

Do I need a separate Responsible Person for the UK?

Yes. Since Brexit, Great Britain requires a Responsible Person based in the UK and a notification in the UK portal (SCPN). Sobel provides this through a qualified partner.

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