EU Cosmetics Compliance — Regulation (EC) No.1223/2009 and Everything It Demands of Your Brand

The EU cosmetics framework is enforced across 27 markets simultaneously. If you are selling in the EU, this is what you are required to have in place.

Regulation (EC) No 1223/2009 governs cosmetic products in the European Union, covering product safety, Responsible Person obligations, Product Information Files, labelling, ingredient restrictions, claims, and post-market surveillance.

For non-EU manufacturers, including UK brands post-Brexit, the requirement is an EU Responsible Person established in an EU member state who takes on legal accountability for the product.

What EU Compliance Requires

An EU Responsible Person established within the EU, legally responsible for product compliance.
A Cosmetic Product Safety Report (CPSR), including Part A (safety information) and Part B (safety assessment by a qualified assessor). A Product Information File (PIF), held at the EU Responsible Person’s address and available to competent authorities for ten years after the last product is placed on the market.
Notification via the Cosmetic Products Notification Portal (CPNP) prior to market placement.
Compliance with EU labelling requirements, including INCI ingredient listing, allergen declarations, mandatory warnings, date of minimum durability or PAO, batch code, and country of origin where applicable.

Post-Brexit: What Changed for UK Brands

Since January 2021, UK-based brands are considered non-EU manufacturers under EU law and must appoint an EU Responsible Person to access the EU market.

This is one of the most consistently underestimated consequences of Brexit for the cosmetics industry. We have seen brands lose EU market access because they did not know this requirement existed.

Get Your EU Compliance in Order