EU & UK Cosmetics Compliance FAQ
What is a Responsible Person in EU cosmetics regulation?
The Responsible Person is the natural or legal person established in the EU who ensures the cosmetic complies with Regulation 1223/2009 — keeping the Product Information File, registering notifications, and handling serious adverse events. A non-EU brand must appoint an EU-based Responsible Person before selling; Great Britain requires a separate UK-established Responsible Person.
What is the difference between CPNP and UK SCPN notification?
CPNP is the EU's Cosmetic Products Notification Portal, used for products sold in the EU, including Northern Ireland. UK SCPN is the UK's Submit Cosmetic Product Notification portal for Great Britain — England, Scotland, and Wales — which operates under UK law mirroring the EU regulation. Brands selling in both markets must notify in both systems, one notification per SKU.
What documents must a private-label brand prepare before selling in the EU?
A Product Information File (PIF) containing the product description, safety assessment by a qualified assessor, manufacturing details, and evidence of claims; an appointed EU Responsible Person; a CPNP notification; and compliant labeling with an INCI ingredient list. All of this must be in place before the first unit is placed on the market.
What are the EU ingredient annexes and how do they affect my formula?
The EU regulates cosmetics by annexes: Annex II lists prohibited substances, Annex III lists restricted substances with maximum concentrations and labeling conditions, and Annexes IV, V, and VI are positive lists for colorants, preservatives, and UV filters. If an ingredient in one of those functions is not on the relevant list, it cannot be used — so every formula's INCI must be checked against the annexes before development.
Can I use my US label on products sold in the EU or UK?
Not as-is. EU and UK labels must include the Responsible Person's name and address, an INCI ingredient list in the required nomenclature, and mandatory information in the official language of the member state where the product is sold. US-style labeling does not automatically transfer, so a separate label version is normally required.
Do private-label brands need a Product Information File if the OEM already has one?
Yes. The OEM may hold manufacturing and formula data, but the Responsible Person must assemble and hold a product-specific PIF that covers the finished product as sold under your brand, including your claims and your label. Ask the OEM for full documentation — formula, safety data, stability and challenge reports — so the PIF can be built; if the OEM cannot supply it, that is a qualification warning.