If you make a product line with different colors, scents, or packaging sizes, a common question is whether you need a separate Cosmetic Product Safety Report (CPSR) for each version. The answer depends on your formulation, not how many SKUs you have.
Understanding the CPSR: What It Covers and Why It Matters
According to EU Regulation 1223/2009, it is against the law not to have a Cosmetic Product Safety Report (CPSR). Its goal is to make sure that all cosmetics sold in the EU are safe for people to use. The CPSR has information about the toxicity of the ingredients, their evaluations, their microbiological assessments, and their stability.
A CPSR only looks at the formulation of a product, not its branding, size, or marketing. That means that two soaps with the same formula but different names won’t need to be tested separately unless the ingredients change.
What Qualifies as a Variant in CPSR Cosmetics?
In cosmetics, a “variant” usually means a product that has the same basic formula but is different in one way, such as scent, color, or size. It depends on how the differences change the product’s toxicological profile whether or not these changes need a new CPSR.
It’s possible to group variants that use the same formula under one CPSR, but not always. This is how to tell.
When Is One CPSR Enough?
Same Formula, Different Sizes
You only need one CPSR if your product comes in different sizes, such as 50ml, 100ml, or 250ml, but the formula and packaging materials are the same. The amount of the product doesn’t change the safety assessment unless the way it is packaged changes how it is stored or used.
Shared Base Formula with Optional Colorants
For color cosmetics like eyeshadow palettes, foundations, and lipsticks that have the “May contain” statement on their ingredient labels (for example, May contain: CI 77491, CI 77492, CI 77499), you can usually share one CPSR. These products all have the same base formula, but they come in different colors or different color percentages so you can use them in different ways.
This grouping doesn’t work for things like soap loaves or bath bombs. For those, each color variant is usually seen as a different formula and may need to be tested separately.
Bundled or Kit Products Using Pre-Assessed Items
You don’t need a new CPSR for kits or gift sets made up of items that have been tested separately if the original formulations stay the same. For example, a holiday box with three lip balms that have been certified separately can use the current CPSRs to make sure it follows the rules.
When a Separate CPSR Is Required
Same Formula, Different Scents (e.g., Fragranced Soaps or Lotions)
Changing the scent of a product isn’t just a change in branding; it also changes the product’s chemical and allergen profile. Different allergens or sensitizers are often found in fragrances. Even if the base stays the same, each fragrance blend needs to be looked at on its own. That means that each scented version needs its own CPSR.
Base Formula Modifications (Functional Ingredients)
Changing the preservatives, emulsifiers, actives, or ratios in a formulation makes it a new product from a safety point of view. A new CPSR is needed because even small changes to the ingredients can change the toxicological thresholds and stability.
Change in the Intended Use
Even if the formula remains unchanged, a change in the intended use of the product (e.g., from a rinse-off to a leave-on application, or from body use to face use) significantly affects how the product interacts with the skin. The duration of contact, area of application, and skin sensitivity vary, and this requires a reassessment of the toxicological profile. Therefore, a separate CPSR is required to ensure the product’s safety under its new intended use.
Real-Life Examples Based on Product Types
Real-world examples can make it easier to understand how product variations are evaluated. The use cases that follow are modeled after websites such as Certified Cosmetics and YouWish, where products are categorized and assessed according to their formulation rather than their name, SKU, or marketing variation:
Example 1: Soap bars in 5 different scents: 5 CPSRs
The toxicological profile changes with each soap because they all have different scents. So, each scent needs its own CPSR.
Example 2: Lipsticks with a “May Contain” colorant list: 1 CPSR
The basic formula for these products is the same. “May contain” lists optional pigments, and they are all looked at together so that one CPSR can cover all shades.
Example 3: Body lotion in 100ml and 250ml: 1 CPSR
The size of the product doesn’t affect safety as long as the formulation and packaging materials stay the same. One CPSR is enough.
Example 4: Eyeshadow palette with 3 different shades: 1 CPSR
If you make shades from the same base and pigments are optional, one CPSR can cover the whole palette.
Example 5: Eau de Parfum with 10 different scents: 10 CPSRs
Every scent has its own toxicological profile and CPSR because it contains different fragrance allergens and ingredients.
Example 6: Same cream formula used as a body lotion and as a face cream: 2 CPSRs
Although the formulation is identical, the intended area of application is different. The skin on the face is more sensitive than the body, and leave-on products for the face require stricter safety considerations. Therefore, a separate CPSR is needed for each intended use.
Assessors Evaluate Formulas, Not SKUs
Safety assessors consider the formulation and intended use when establishing CPSR requirements; they do not consider product names, different sizes, or the number of SKUs. They assess the ingredient list, potential interactions, and exposure risks to ensure the product is safe for its intended use.
For example, if colorants are optional and marked as “May contain,” then ten lipstick shades made with the same base formula might only require one CPSR. However, due to varying allergen profiles, each new scent that is added to a soap or lotion needs to be evaluated independently.
In short, CPSRs follow formulas and cosmetic functions instead of marketing changes. The underlying composition decides the regulatory path, whether you sell just one item or a whole range of them.
FAQ: CPSRs for Cosmetic Variations
Do different sizes need separate CPSRs?
No, if the formulation and packaging material are the same, size variations by themselves do not necessitate separate reports.
Can color variations share one CPSR?
Yes, provided the product is made with a base formulation and pigments that are marked “May contain” are used at levels that are permitted.
Do different scents need different CPSRs?
Yes. Every fragrance has a different safety profile and contains a different set of allergens.
What if I change just the packaging?
The original CPSR is still valid as long as the packaging doesn’t affect stability, exposure, or preservation.
Conclusion: Think Formula and intended use, Not SKU
The most important thing to think about when deciding how many CPSRs you need is your formulation and intended use. Changes in smell, color, and packaging may not seem like a big deal, but they can have a big impact on safety and the law.
If you’re not sure if your products need their own reports, we can help. You can also get more help from our CPSR services or the Certified Cosmetics blog.
