EU Product Safety Reform Brings Additional Obligations for Cosmetic Products

The European Union’s General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, represents one of the most significant updates to consumer product safety legislation in recent years. Although the regulation officially became applicable on 13 December 2024, its practical implications continue to evolve, particularly following the publication of new European Commission guidance in November 2025.

For companies operating in the cosmetics sector, the GPSR does not replace existing cosmetic legislation. Instead, it introduces additional requirements, especially for products sold online or through other forms of distance selling. As e-commerce continues to grow across Europe, regulators are seeking to ensure that consumers receive the same level of safety information online as they would in a physical store.

Why Was the GPSR Introduced?

The GPSR replaces the former General Product Safety Directive (GPSD), a framework that had been in place for more than two decades. While the previous legislation established important safety principles, it was developed before the rapid expansion of online marketplaces, cross-border e-commerce, and digital retail platforms.

The new regulation aims to address these developments by strengthening consumer protection and improving the ability of authorities to identify, trace, and remove unsafe products from the market.

Among its main objectives are improving product traceability, facilitating recalls, increasing transparency for consumers, strengthening market surveillance, and introducing clearer responsibilities for online marketplaces and economic operators throughout the supply chain.

Under the regulation, a product is considered safe when it presents no risk—or only minimal acceptable risks—to consumer health and safety under normal or reasonably foreseeable conditions of use. Importantly, product safety is no longer viewed as a static concept. Manufacturers are expected to continuously assess risks in light of technological developments, scientific knowledge, and changing patterns of consumer behaviour.

What Does the GPSR Mean for Cosmetic Products?

Cosmetic products placed on the EU market remain primarily regulated by the Cosmetics Regulation (EC) No. 1223/2009. However, the GPSR introduces additional obligations in areas that are not fully covered by cosmetics legislation, particularly regarding distance selling.

This means that cosmetic brands, manufacturers, importers, and retailers selling products online must ensure compliance with both regulatory frameworks.

One of the most important provisions for the cosmetics sector is Article 19 of the GPSR, which specifies the information that must be made available to consumers before a purchase is completed through an online channel.

Online Sales Requirements

In November 2025, the European Commission published long-awaited guidance on the implementation of the GPSR. The document provides practical clarification on how businesses should comply with the regulation and aims to support consistent enforcement across EU Member States.

For cosmetic products sold online, the guidance confirms that consumers must have easy access to key product information before making a purchase.

This information includes the identity of the manufacturer or responsible person, their postal and electronic contact details, information allowing clear identification of the product, and any relevant safety warnings or precautions for use.

The guidance also clarifies that product descriptions should include details such as the product name, brand, function, available shades, and available sizes where relevant. If this information is clearly visible in product photographs, it does not necessarily need to be repeated elsewhere on the product page.

Increased Focus on Traceability and Risk Management

Beyond online sales requirements, the GPSR places greater emphasis on traceability and risk management throughout the product lifecycle.

Economic operators are expected to maintain adequate technical documentation, carry out risk assessments, and ensure that products can be traced through the supply chain when necessary. The regulation also reinforces obligations related to incident reporting, corrective actions, product recalls, and cooperation with market surveillance authorities.

These measures are intended to improve the speed and effectiveness of responses when safety concerns arise.

Industry guidance indicates that compliance is a shared responsibility between the Responsible Person and the retailer offering products through distance-selling channels.

The Responsible Person must ensure that the required information is accurate, complete, and kept up to date. Online retailers and marketplaces, meanwhile, are responsible for displaying this information clearly and prominently to consumers before purchase.

As a result, many companies are reviewing contractual arrangements with distributors, retailers, and marketplace operators to clarify compliance responsibilities.

Language Requirements Across the European Market

The GPSR also reinforces the importance of making safety information available in a language that consumers can easily understand.

Warnings, precautions for use, and other safety-related information must generally be translated into the official language or languages required by each Member State where the product is sold.

However, the name and contact details of the Responsible Person typically do not need to be translated, except where different writing systems or alphabets are involved.

Stronger Enforcement and Higher Risks for Non-Compliance

The regulation provides national authorities with broader powers to monitor compliance and take action against unsafe products.

Companies that fail to meet their obligations may face financial penalties, corrective measures, product withdrawals, or recalls, depending on the nature and severity of the infringement.

The GPSR also strengthens the role of Safety Gate, the EU’s rapid alert system for dangerous non-food products. Through this platform, national authorities can quickly exchange information about unsafe products, helping coordinate enforcement actions across the European market.