White label cosmetics create valuable business opportunities for manufacturers who want to scale distribution and for distributors who want to launch products under their own brand. However, the regulatory structure behind a white label product must be carefully defined from the start.

For manufacturers, maintaining control over the formulation, Product Information File (PIF), and regulatory responsibility can be essential to protect intellectual property and ensure consistent compliance across multiple clients.

For distributors, taking ownership of the brand often means becoming the Responsible Person and managing a fully independent PIF in their own name. This requires a clear transfer of documentation and regulatory accountability.

This whitelabel CPSR service is designed to support both models. Whether you remain the Responsible Person or transfer responsibility to the distributor, we ensure that the regulatory framework is correctly structured, documented, and compliant with Regulation (EC) No 1223/2009.

How does the whitelabel PIF and CPSR work

This Cosmetic Product Safety Report (CPSR) service is exclusively available for whitelabel products for which we have previously prepared the original PIF and/or CPSR. If a whitelabel PIF and CPSR is required for an existing which has not been created by Certified Cosmetics, we will first need to recreate it. This service would be required first: Cosmetic Product Safety Report – CPSR

There are two possible regulatory scenarios for whitelabel products:

1. The whitelabel manufacturer remains the Responsible Person (RP)

2. The distributor becomes the Responsible Person (RP)

Each scenario has different legal requirements and deliverables.

The whitelabel manufacturer remains the Responsible Person

In this situation, the original manufacturer continues to act as the Responsible Person under Regulation (EC) No 1223/2009.

Requirements:

• The manufacturer’s name and address must appear on the product label.

• The Product Information File (PIF) and CPSR remain under the control of the manufacturer.

• The formulation remains confidential and managed by the manufacturer.

This structure ensures that the manufacturer retains control over the recipe and regulatory documentation.

Deliverables:

• Label compliance check (Article 19 review)

• Annex to the existing PIF reflecting the whitelabel arrangement

The distributor will become the Responsible Person

If the distributor wishes to place the product on the market under their own name and assume full regulatory responsibility, they must act as the Responsible Person.

Requirements:

• The distributor must establish and maintain their own Product Information File (PIF).

• Regulatory responsibility transfers to the distributor.

Deliverables:

• Label compliance check (Article 19 review)

• New PIF issued in the name of the distributor

• We can also submit this to CPNP with this service: CPNP notification service