Selling cosmetics online can be fun, but in the EU, there are strict rules you have to follow. Having a Cosmetic Product Safety Report (CPSR) for each product is one of the most important things that new sellers forget to do.
You might think that skipping this step is a quick way to get things done, but it could have serious legal consequences, get you banned from the platform, and damage your brand’s reputation beyond repair.
This guide tells you exactly why the CPSR is not up for discussion, what could happen if you don’t follow it, and how to make sure you are compliant before you launch your products.
What Is a CPSR and Why Is It Mandatory?
Definition of CPSR under EU Regulation 1223/2009
EU Regulation (EC) No 1223/2009 says that cosmetics must have a CPSR. It is a scientific safety assessment done by a qualified expert that shows your product is safe to use in normal and reasonably expected situations.
If you don’t have this document, your cosmetic is automatically not allowed in the EU. That means you can’t sell it legally, whether it’s on your own website, in a store, or on an online marketplace.
There are two parts to a valid safety report for a cosmetic product:
Part A: Safety of Cosmetic Products Information: includes the formula, ingredient specifications, toxicological profiles, product stability, microbiological quality, packaging compatibility, and exposure scenarios.
Part B: Cosmetic Product Safety Assessment: A qualified safety assessor gives their professional opinion that the product is safe for people to use.
The Role of the Safety Assessor
A CPSR can only be given by a qualified safety assessor, who is usually a toxicologist, pharmacist, or chemist with the right credentials. Their job is to:
- Check each ingredient and how much of it there is.
- Check for toxic and allergic risks.
- Make sure the product meets the ingredient limits set out in Annex II and Annex VI of the EU Cosmetic Regulation.
- Make sure the product is microbiologically safe and will stay that way for the time it is meant to be on the shelf.
Legal Requirements for Selling Cosmetics Online in the EU
CPSR as Part of the Product Information File (PIF)
Your main compliance document is the Product Information File (PIF). It has to be at the Responsible Person’s EU address and ready for market surveillance authorities to look at at any time.
A PIF has:
- CPSR (Parts A and B)
- Description of the product
- Proof of GMP compliance and the method of making
- Proof of claimed effects, like SPF test results for sunscreens
- Putting labels on art and translating languages
- Results of tests for safety and effectiveness
Your PIF is not complete without a CPSR, which means your product is not legal to sell.
Notification to the CPNP Platform
You need to register your product on the Cosmetic Product Notification Portal (CPNP) before you can sell it. Poison control centers, customs, and regulatory agencies all over the EU use this database.
To finish the notification, the CPNP needs information from your CPSR. You can’t register your product without a CPSR, which means you can’t sell it in the EU.
The Risks of Selling Cosmetics Without a CPSR
It’s not just “bending the rules” to sell cosmetics without a CPSR; it’s against the law in the EU. This is what you could lose:
Financial Penalties and Legal Fines
Selling cosmetics without a CPSR for cosmetics can result in significant financial penalties. In the EU, each member state enforces cosmetic regulations through its national authority, and the fines vary by country. For example, in France, the DGCCRF can issue penalties of up to €37,500 for each noncompliant product. In Germany, the BVL can impose fines reaching €50,000, while in Italy, the amount can exceed €100,000 for severe breaches that pose a risk to public health. These amounts are per product and incident, which means multiple SKUs without a cosmetic product safety report could quickly multiply the cost. Beyond official fines, businesses also face indirect costs such as product recalls, full refunds to customers, loss of unsellable stock, and substantial legal expenses. For small brands, these combined costs can be devastating.
Product Bans and Immediate Market Withdrawals
Regulatory bodies in the EU have the authority to issue stop-sale orders immediately if they discover that a cosmetic product is being sold without a valid CPSR. This often means removing the product from your online store, taking down listings from marketplaces, and recalling sold items from customers. In some cases, authorities will seize and destroy remaining stock to prevent it from re-entering the market. Such enforcement actions are often made public, with the violation published on official channels. This transparency is intended to protect consumers, but it also means your brand could suffer long-term visibility as a non-compliant seller.
Liability for Consumer Harm or Allergic Reactions
The CPSR is more than just a formality; it is your documented proof that a product is safe. Without it, you cannot demonstrate that your cosmetic has undergone the required toxicological assessment. If a customer experiences an allergic reaction, skin irritation, or other health issue linked to your product, you could face legal claims and compensation demands. The absence of a CPSR weakens your defense in court, and in many cases, business insurance will not cover damages caused by products that were sold illegally. This could leave you personally liable for all related medical costs, legal fees, and settlements.
Platform Bans (Amazon, Etsy, Notino, etc.)
Online marketplaces are increasingly strict about regulatory compliance. Amazon EU, Etsy, and Notino all require CPSR documentation before allowing cosmetics to be listed. Failure to provide this documentation can result in the immediate removal of your listings, suspension of your seller account, and in some cases, the withholding or destruction of inventory stored in fulfillment centers. Once a seller account is suspended due to compliance issues, reinstatement is extremely challenging, and the loss of marketplace access can significantly reduce your sales channels.
Reputational Damage and Loss of Trust
Even if no one is harmed by your product, a single compliance violation can seriously damage your brand reputation. News of a stop-sale order, recall, or regulatory fine can spread quickly on social media, review platforms, and consumer rights websites. Once trust is broken, it can be extremely difficult to rebuild, especially in a competitive market where consumers have many other compliant alternatives to choose from. Maintaining full compliance is not just about avoiding fines; it is about demonstrating to your customers that you take their safety seriously.
How to Ensure Your Cosmetic Products Are Legally Compliant
Work with a Certified CPSR Provider
Achieving compliance in the EU cosmetics market starts with working alongside a qualified CPSR for cosmetics providers. Preparing a Cosmetic Product Safety Report is a specialized process that requires toxicological expertise, in-depth knowledge of EU Regulation 1223/2009, and a full understanding of ingredient safety data. At Certified Cosmetics, our safety assessors review your full formulation, raw material documentation, and manufacturing process to ensure every element meets legal and scientific standards. This professional oversight not only ensures your report is valid but also reduces the risk of costly errors that could delay your market launch.
Prepare a Complete Product Information File (PIF)
The CPSR is just one part of the legally required Product Information File, which acts as a complete compliance record for each cosmetic product you sell. Your PIF must be maintained at your Responsible Person’s EU address and be readily available to market surveillance authorities. A complete PIF should include CPSR Parts A and B, a full INCI ingredient list, stability and preservative efficacy test results, GMP (Good Manufacturing Practice) evidence, and translated labels for every country where you sell your product. Missing even one of these elements can lead to your PIF being considered incomplete, making your product non-compliant by default.
Submit to the CPNP Before Going Live Online
Before listing your cosmetics for sale, even for pre-orders, you must submit your product information to the Cosmetic Product Notification Portal (CPNP). This EU-wide database allows authorities, poison centers, and customs officials to quickly identify your product and review its safety data if needed. The CPNP submission requires details from your CPSR, meaning it’s impossible to complete this step without a valid report. Launching a product online before completing CPNP notification is a direct violation of EU law and could lead to immediate product removal and fines.
What Certified Cosmetics Can Do for You
CPSR Services for EU Market
At Certified Cosmetics, we specialize in delivering CPSR for cosmetics that are fully compliant with EU Regulation (EC) No 1223/2009. Our services are designed to support a wide range of clients, from small indie brands launching their first product to established manufacturers expanding into new markets. Each safety report is prepared by qualified toxicologists who assess your product’s ingredients, concentrations, and intended use to ensure it meets all regulatory requirements. By working with us, you can be confident that your documentation will pass regulatory inspections and platform compliance checks without delays.
Save Time, Avoid Legal Risks
Our goal is to simplify the compliance process so you can focus on growing your brand. With Certified Cosmetics, you don’t just receive a safety report; you receive a complete, ready-to-use compliance package. We guide you through gathering the required documentation, ensure that your Product Information File is complete, and prepare you for CPNP submission. This proactive approach helps you avoid costly mistakes, prevents last-minute compliance issues, and ensures your products are ready for sale in every EU member state from day one.
FAQ: Selling Cosmetics Without a CPSR
Q1. Is it possible to sell cosmetics I made myself without a CPSR?
No. All cosmetics, even those that are handmade or made from natural ingredients, need a CPSR before they can be sold in the EU.
Q2. What will happen if I get caught selling without a CPSR?
You could get heavy fines, have to recall your products, and be banned from the platform.
Q3. Do Etsy or Amazon need a CPSR?
Yes. They might ask for it before they let you list your goods.
Q4. How long does it take to get a CPSR?
It usually takes 3 to 10 business days, depending on how complicated your product is.
Q5. Is the CPSR the same thing as the PIF?
No. There are other compliance documents in the PIF, and the CPSR is one of them.
Conclusion
If you sell cosmetics without a CPSR, you are taking a big risk that could cost you money, your business, and your good name. The cosmetic product safety report is more than just a piece of paper; it’s your legal way to get into the EU market and show that your brand cares about the safety of its customers.
We’re here to help you make sure your products are compliant.
Check out our CPSR Services and feel good about launching your cosmetics.
