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Placing Your Cosmetics on the EU Market

The Cosmetic Regulation 1223/2009 has enforced several obligations when it comes to placing a cosmetic and personal care product on the European market. For most manufacturers and distributors of the cosmetics & personal care products industry, the European Cosmetic Regulation no 1223/2009 enforces measures that have to be fulfilled before placing a cosmetic product on the European market: appointment of a Responsible Person, creation of the Product Information File, labelling compliance, CPNP notification, and more.

The first major step of Regulation 1223/2009: every cosmetic brand must appoint a Responsible Person (RP), natural or legal, within the European Union, for each and every cosmetic product placed on the European market. A, RP is a natural or legal person established in the European Community acting for all the European countries at once. The RP can be a consulting firm, a manufacturer, an importer, or a distributor.

The second crucial step to validate before placing your cosmetic products on the market, is to review the composition or formula of your cosmetic product on a regulatory perspective, i.e. against the Annexes of the Regulation. Some ingredients are prohibited, restricted or allowed by the Cosmetic Regulation. You should make sure that the product that you want to place on the market is fully compliant with the Annexes of the Regulation outlining these restrictions.

Another prerequisite to place your cosmetic product on the EU market is the constitution of the Product Information File (PIF). The PIF has to be made available for the authorities, which can consult it at any time (electronic or paper). The drafting and the keeping of the PIF is mandatory even for cosmetic placed on the market before the entry into force of the Regulation (2013).

You must create compliant labels that include:

  • Name and address of the Responsible Person
  • Country of origin
  • Nominal content
  • Date of minimum durability or period-after-opening
  • Precautions & warnings*
  • Batch number
  • Product function*
  • Ingredients list

Lastly, the Responsible Person must notify the European Commission via the CPNP portal. Cosmetics Products Notification Portal (CPNP): CPNP is the online notification portal created for the enforcement of Regulation (CE) No 1223/2009 by the European Parliament and the Council of Cosmetic Products. It is a website that Responsible Persons and Authorities can use to access products’ information.