It’s exciting to be able to sell your face cream line in the EU, but you will have to follow strict rules. Every step, from checking the safety of the product to putting on the right labels, must follow EU Regulation 1223/2009. This guide tells you everything you need to know to legally start selling face creams in the EU.
Why Compliance Matters When Selling Face Creams in the EU
The cosmetic market in the European Union is one of the most tightly controlled in the world. EU Regulation 1223/2009 says that all cosmetics, including face creams, must meet safety, documentation, and labeling standards.
What Makes Face Creams a “Higher-Risk” Product?
Many face creams have active ingredients, preservatives, and emulsifiers that can affect the skin barrier. This makes safety checks, stability tests, and microbiological tests even more important.
Step 1: Finalize Your Face Cream Formula
First and foremost, your formulation needs to be complete and stable.
Why Ingredient Transparency Is Essential
You must use INCI (International Nomenclature of Cosmetic Ingredients) language to list all the ingredients. You can’t have hidden or unclear ingredients.
INCI Naming and “Saponification” Notes
For ingredients like oils that go through saponification, the final product’s composition must be listed, not just the raw materials.
Step 2: Conduct Required Safety Assessments
What Is a Cosmetic Product Safety Report (CPSR)?
Before a product can be sold in the EU, it must have a CPSR, which is a safety document. It is made up of:
Part A: Information about the product, such as its composition, toxicological profile, stability, and so on.
Part B: A signed safety report from a qualified toxicologist.
Who Can Issue a CPSR and What You’ll Need
Only qualified safety assessors can issue a valid CPSR. You’ll need to provide:
- Final formulation with percentages
- Certificate of analysis for raw materials
- Stability and microbiological test results
- Packaging specs and intended use
Certified Cosmetics can assist you in compiling and reviewing all required data.
Step 3: Create a Product Information File (PIF)
What Needs to Be in the PIF for Face Creams?
The Responsible Person’s address must be where EU authorities can get to your PIF. It has to have:
- CPSR (Parts A and B)
- What the product is
- Proof of GMP and the way things are made
- Proof of claims, like “anti-aging”
- Art for labels
Results from tests, such as stability, microbiological, and challenge tests.
PIF Storage and Access Rules
The PIF must be kept for 10 years after the last batch is sold, and it must be easy for the right people to get to.
Step 4: Perform Stability and Microbiological Testing
Why These Tests Are Critical for Face Creams
Water is a common ingredient in face creams, which makes it easy for microbes to grow. This means that microbiological testing is necessary, especially if the product will be kept in jars or tubs.
Shelf Life Testing and Packaging Compatibility
To make sure a product stays stable over time, stability tests should be done in conditions that are similar to those in the real world (heat, light, transport). You should also make sure that the formula works with the packaging.
Exceptions to Consider
Some microbiological tests may not be needed for products that are anhydrous, single-use, or have a lot of alcohol in them, but they still have to be safe.
Step 5: Label Your Product the Right Way
Mandatory EU Labeling Elements for Face Creams
Your label needs to have:
- The name of the product and what it is supposed to do
- Nominal content, like 50 mL
- The PAO symbol stands for “Period After Opening.”
- Lot code or batch number
- Things to keep in mind when using
- List of ingredients (INCI)
- Name of the manufacturer and address in the EU
Language, Font Size, and Placement Guidelines
All information must be easy to read, see, and understand, and it must be in the official language(s) of the country where the product is sold.
Step 6: Notify Your Face Cream via the CPNP
What Is the Cosmetic Product Notification Portal (CPNP)?
The European Commission runs the CPNP, which is a free online notification system. Before any cosmetic product can be sold legally in the EU, it must be notified.
How to Submit Your Product Through the Portal
You will need to give:
- Name and type of product
- Picture and label of the product
- List of all ingredients (INCI)
- CPSR Responsible Person information
Certified Cosmetics helps with the whole CPNP submission process, from making an account to uploading documents.
How Certified Cosmetics Can Help
Certified Cosmetics is the company to work with if you want to launch one face cream or a whole line of skincare products. We have:
CPSR Creation for Face Creams
Our toxicologists write reports that are completely in line with your formulation and packaging.
Stability & Microbiological Test Support
We work with certified labs to make sure that all the tests your product needs are done on time.
Guidance on Labeling and CPNP Notification
We help you make labels that follow the rules and send in your face cream through the CPNP without any stress.
Frequently Asked Questions (FAQ)
Q1. Do I need a separate CPSR for each face cream variant?
Yes. Even if the only difference is the scent or active ingredients, each unique formula needs its own CPSR.
Q2. Can I sell a handmade face cream in the EU?
Yes, but handmade goods must follow the same rules as mass-produced ones, such as PIF, CPSR, and CPNP notification.
Q3. Are natural or organic face creams exempt from testing?
No. Natural or organic products still have to pass safety, microbiological, and stability tests to meet EU rules.
Q4. What is the cost of compliance for one face cream product?
Costs depend on how many tests need to be done and how complicated the formulation is. Get in touch with Certified Cosmetics to get a quote that fits your product.
Conclusion: Compliance Is Key to Long-Term Success
If you want to sell face creams in the EU, you need more than just a good product. You need to pay attention to the law at every stage, from writing up documents to testing and labeling products. We make the regulatory process at Certified Cosmetics clear, easy to understand, and quick so you can build your brand with confidence.
Want to learn more about selling cosmetics in the EU?
You can find expert guides like this one on our blog, or you can look into our services to get started with your CPSR, product testing, and full compliance support.