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EU cosmetic regulation: who is responsible, and what gets filed

The EU system is easier to follow as a chain of responsibility than as a list of article numbers. One entity has to be established in the EU and stand behind the product; everything else hangs off that.

The one-line answer: before an EU product can be placed on the market, a responsible person established in the EU must be named, a safety assessment must exist, a product information file must be kept, and the product must be notified — and none of those steps is an approval.

The chain of responsibility

  1. The brand decides to place the product on the EU market.
  2. The responsible person must be established in the EU and is named on the label. It is the entity the authorities hold to account.
  3. The safety assessor produces the safety assessment, which must exist before the product goes on the market.
  4. The product information file is kept by the responsible person and must be available to the authorities on request.
  5. CPNP notification is filed by the responsible person before the product is placed on the market.

The governing instrument is Regulation (EC) No 1223/2009. The full text, including the annexes that set out permitted and restricted substances including colourants, is published at EUR-Lex.

What the EU label has to carry

The EU regime sets out required label information, and the practical items buyers trip over are:

Colourants are an EU positive list. Only colourants permitted by the regulation may be used, and they are set out in the regulation's annexes rather than left to a national authority. A colour lawful in the US is not automatically lawful in the EU — check the annex, not a supplier's summary.

Notification is not authorisation

Filing through CPNP tells the authorities that the product exists. It does not mean the product has been reviewed or approved, and it does not transfer responsibility away from the responsible person. Treating the notification as a green light is one of the most common misunderstandings about the EU system — the same distinction that applies to US registration, explained in who files what in cosmetics compliance.

Where this meets manufacturing

The safety assessment depends on the formula, and the formula depends on the factory. If the product contains colour, the permitted list becomes a manufacturing constraint as well as a labelling one — see colour cosmetics requirements.

Related reading

Frequently asked questions

Does an EU cosmetic need approval before it can be sold?

No. The EU system is based on notification and self-assessment rather than pre-market approval. A responsible person must be established in the EU, a safety assessment must exist, and the product must be notified before it is placed on the market.

Who can be the responsible person for the EU?

The responsible person must be established in the EU and is named on the product label. It is the entity the authorities hold accountable, so brands outside the EU need an EU-established representative.

What is the CPNP notification?

It is the portal through which the responsible person notifies a product. It confirms the product has been notified; it is not a marketing authorisation and does not constitute approval.

What is the product information file?

The file the responsible person must keep, including the safety assessment and supporting data, and must make available to the authorities on request.

Are US-approved colours valid in the EU?

Not automatically. The EU uses a positive list of permitted colourants set out in the regulation's annexes, so a colour lawful in the US may not be lawful in the EU. Check the annex rather than a supplier summary.

What has to be on the EU cosmetic label?

The required information includes the responsible person's name and address in the EU, the nominal content, any warnings and use-by or period-after-opening information, and an ingredient list in the international naming convention.