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, which 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
Every EU country has its own way of enforcing the rules, but the fines for not following them are high. For instance:
- France (DGCCRF): Each product that doesn’t follow the rules can be fined up to €37,500.
- Germany (BVL): Fines can be as high as €50,000, plus court costs.
- Italy: In very bad cases, fines can be more than €100,000.
And these numbers don’t include the costs of recalling products, giving customers their money back, or hiring lawyers.
Product Bans and Immediate Market Withdrawals
If authorities find out you’re selling without a CPSR, they can tell you to stop right away. They will do this in some cases:
- Ask customers to return all of the products.
- Take away the rest of your stock.
- Make the violation public, which can hurt your brand for a long time.
Liability for Consumer Harm or Allergic Reactions
You can’t prove that your product is safe without a cosmetic product safety report. You could be sued or have to pay damages if a customer has an allergic reaction or another bad reaction, and your insurance might not cover you if you were selling illegally.
Platform Bans (Amazon, Etsy, Notino, etc.)
Online marketplaces are making their compliance checks stricter. For instance, Amazon EU requires sellers to show CPSR paperwork before they can list any cosmetic product. Without it, you could:
- Immediate removal of listings.
- Suspension of the seller’s account for good.
- Not being able to get to stored stock in fulfillment centers.
Reputational Damage and Loss of Trust
A single violation of compliance can hurt your reputation. Once people discover on social media or in reviews that your products have been banned, it can be very challenging to regain their trust.
How to Ensure Your Cosmetic Products Are Legally Compliant
Work with a Certified CPSR Provider
Working with experts makes sure that your CPSR meets all legal and scientific requirements. Before we send you the report, our toxicologists at Certified Cosmetics look over your full formulation, raw material documentation, and manufacturing process.
Prepare a Complete Product Information File (PIF)
Be sure to include the following in your PIF:
- CPSR (Parts A and B) and a full list of INCI ingredients
- Results of tests for stability and preservative effectiveness
- Label translations for every language you sell in the EU GMP certification, or manufacturing documents.
Submit to the CPNP Before Going Live Online
Don’t ever list a cosmetic online, even for “pre-orders,” until the CPNP has fully notified you. This ensures that you are legally protected if market surveillance reviews your listings.
What Certified Cosmetics Can Do for You
CPSR Services for EU Market
We offer CPSR for cosmetics that meet all the requirements of EU Regulation 1223/2009. We work with both small, independent brands and large manufacturers, and we consistently deliver on time without compromising quality.
Save Time, Avoid Legal Risks
You don’t just get a safety report with our services; you also get peace of mind. We make sure that your paperwork is ready for inspections, platform checks, and sales across borders.
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.
