GPSR for Cosmetics and Beauty Products: Cosmetics Regulation 1223/2009, Responsible Person, Labels and Amazon EU

First, sort your catalogue: cosmetic, beauty device or beauty tool?

The beauty category mixes three kinds of product regulated in completely different ways. Under Article 2(1)(a) of the Cosmetics Regulation, a cosmetic is a substance or mixture applied to the external parts of the body, the teeth or the oral mucous membranes, mainly to clean, perfume, change appearance, protect, keep in good condition or correct body odours.

Three traps to watch. The Low Voltage Directive only covers equipment rated between 50 and 1,000 V AC or 75 and 1,500 V DC, so many USB-powered gadgets fall outside it and their electrical and heat safety is assessed under the GPSR instead. Products claiming to treat acne, regrow hair or heal eczema risk being classified as medicines or medical devices rather than cosmetics. And kits such as "lamp + gel polish + tools" must be compliant component by component. For devices, see the electronics white paper.

The core of the Cosmetics Regulation: Responsible Person, safety report, PIF and CPNP

The Cosmetics Regulation is a complete market-access system of its own, and it replaces the GPSR's general duties on technical documentation and labelling. Five building blocks matter most to sellers.

1. The cosmetics Responsible Person

Under Article 4, only cosmetic products for which a legal or natural person is designated within the EU as "responsible person" may be placed on the market. An EU manufacturer is the Responsible Person by default. A manufacturer outside the EU, such as a Chinese brand owner, must designate an EU-based person by written mandate, and that person must accept in writing. Each importer is the Responsible Person for the products it places on the market, unless it mandates someone else in writing. A distributor becomes the Responsible Person if it sells under its own name or trademark or modifies a product in a way that may affect compliance; translating label information alone does not count. Article 5 sets out the duties: ensure compliance with the Regulation, take immediate corrective action, withdrawal or recall where a product is non-compliant, inform the authorities where there is a risk to health, and cooperate with them.

This is not the same role as the GPSR Article 16 responsible person. Sellers often call both "EU rep", but the legal basis, scope and duties differ:

Because cosmetics are covered by Union harmonisation legislation, Chapter III Section 1 of the GPSR (which contains Article 16) does not apply to them. A cosmetics seller therefore needs a Responsible Person under the Cosmetics Regulation, while the brushes and mirrors in the same shop need a GPSR responsible person. Many providers can do both, but the contract must say which role they take on and for which products. The GPSR rules are explained in who the EU responsible person is.

2. Cosmetic Product Safety Report (CPSR)

Article 10 requires a safety assessment and a safety report drawn up in line with Annex I before the product is placed on the market. The assessor must hold a university-level qualification in pharmacy, toxicology, medicine or a similar discipline, or an equivalent recognised course. The report must be kept up to date when the formula or data change.

3. Product Information File (PIF)

Article 11 requires a PIF for each product: a product description, the safety report, a description of the manufacturing method with a statement of compliance with good manufacturing practice, proof of claimed effects where justified, and data on any animal testing. It must be readily accessible at the Responsible Person's address shown on the label, in a language the authorities easily understand, and kept for ten years after the last batch was placed on the market. Good manufacturing practice is required by Article 8; the harmonised standard EN ISO 22716 is the usual reference.

4. CPNP notification

Under Article 13, the Responsible Person notifies each product on the Cosmetic Products Notification Portal (CPNP) before launch: category and name, Responsible Person, country of origin, first Member State of sale, nanomaterials, CMR substances and frame formulation. Label and packaging photos follow after launch. Nanomaterials also need prior notification under Article 16.

5. Formula compliance: the annexes keep moving

Annex II (prohibited substances), Annex III (restricted substances) and Annexes IV–VI (colorants, preservatives, UV filters) are amended frequently. A recent example that hit many nail-product sellers: Commission Regulation (EU) 2025/877 added the photoinitiator TPO (trimethylbenzoyl diphenylphosphine oxide) to Annex II. From 1 September 2025, products containing TPO may neither be placed on the market nor made available. Article 18 also bans marketing products tested on animals in breach of the Regulation.

What the GPSR does and does not do for cosmetics

GPSR Article 2(1) says that where products are subject to specific safety requirements under EU law, the GPSR applies only to the aspects, risks or categories of risk not covered by those requirements. The Cosmetics Regulation is listed in Annex I to Regulation (EU) 2019/1020, so it counts as "Union harmonisation legislation" under GPSR Article 3(27). For such products, Article 2(1) adds that Chapter II applies only to risks not covered, and that Chapter III Section 1, Chapters V and VII and Chapters IX to XI do not apply. The Commission's business guidelines (Commission Notice C/2025/6233, November 2025) gives the same list.

Online offers: GPSR Article 19

Article 19 requires every online offer to show clearly and visibly: (a) the manufacturer's name or trademark with postal and electronic address; (b) for non-EU manufacturers, the responsible person's name, postal and electronic address; (c) product identification, including a picture and type; and (d) any warning or safety information required on the pack, in a language set by the Member State. For cosmetics, point (d) means the precautions under Article 19(1)(d) of the Cosmetics Regulation. Point (b) refers to the responsible person under GPSR Article 16(1) or Article 4(1) of Regulation (EU) 2019/1020, neither of which strictly covers cosmetics; industry guidance (for example from Cosmetics Europe) is to display the cosmetics Responsible Person. The text does not spell this out, so follow the latest position of authorities and platforms. Platform-by-platform steps are in GPSR information you must show online.

Accident reporting and serious undesirable effects

Article 23 of the Cosmetics Regulation requires the Responsible Person and distributors to notify serious undesirable effects (SUEs) without delay to the authority of the Member State where they occurred. GPSR Article 20 requires accidents causing death or serious harm to be notified through the Safety Business Gateway. The Commission lists Chapter III Section 2 as applicable to harmonised products, but the text does not say how the two duties combine, given that specific provisions with the same objective take precedence under Article 2(1). The prudent approach: always meet the SUE duty, and for other incidents (a glass jar shattering, an aerosol can bursting) assess whether a GPSR Article 20 notification is needed, asking the authority or a lawyer if in doubt. See accidents, recalls and Safety Gate.

Cosmetics labelling: Article 19 of the Cosmetics Regulation, item by item

Article 19(1) requires the following information on the container and outer packaging, in indelible, easily legible and visible lettering.

Language: for items (b), (c), (d) and (f), the language is set by the law of the Member State where the product reaches the end user, which in practice means multilingual packs for multi-country selling. The ingredient list uses common ingredient names (based on INCI) and is not translated. If the pack is too small, Article 19(2) allows precautions and ingredients to go on an enclosed leaflet, tag or card, signalled on the pack by the "hand in book" symbol (Annex VII, point 1); soaps and bath balls may show ingredients on a notice near the point of sale under Article 19(3). QR codes can add languages or detail but cannot replace the printed information: GPSR Article 21 treats electronic formats as an addition only, and recital 32 says digital means such as QR codes could provide information "in addition", so digital-only labelling is not enough.

Beauty tools and devices follow GPSR Article 9 labelling instead (type, batch or serial number, manufacturer details, responsible person, local-language instructions); see the GPSR label requirements guide. To draft label text quickly, you can use our sister tool gpsrtools.com and then check every line against the table above.

Product claims: Article 20 and Regulation (EU) No 655/2013

Claims include listing titles, bullet points, A+ content and image text, not just the pack. Article 20 forbids anything implying characteristics or functions the product does not have. Commission Regulation (EU) No 655/2013 sets six common criteria that every cosmetic claim must meet:

1. Legal compliance: you cannot sell a legal requirement as a special benefit;
2. Truthfulness: the ingredient or effect you claim must really be there;
3. Evidential support: keep adequate evidence, which belongs in the PIF;
4. Honesty: no exaggeration;
5. Fairness: no denigrating competitors or lawfully used ingredients;
6. Informed decision-making: claims must be clear to the average consumer.

The usual problems: medical claims ("treats", "regrows hair") that push a product towards medicines; "free from" claims for ingredients banned anyway, which mislead; and "not tested on animals", which Article 20(3) allows only if neither the finished product, its prototype nor any ingredient was tested on animals. Have translated marketing copy reviewed by someone who knows the rules.

Beauty tools and devices: where the GPSR applies directly

Beauty tools have no product-specific EU safety law, so the GPSR is the main rule. The manufacturer must carry out an internal risk analysis and draw up technical documentation (Article 9(2)), kept for ten years; the product must carry a type, batch or serial number and the manufacturer's name or trademark with postal and electronic address (Article 9(5) and (6)); and it must come with instructions and safety information in the local language (Article 9(7)). A manufacturer outside the EU needs an EU-based responsible person whose details appear on the product, packaging, parcel or an accompanying document (Article 16). How to build the file is explained in GPSR technical documentation and risk assessment.

Typical risks to cover in the assessment:

• Sharp edges: brow razors and nail clippers need blade protection and safe storage design;
• Appeal to children: cartoon-style brushes or mini sponges may attract children, and Article 6 requires you to consider vulnerable consumers, adding age warnings where needed;
• Materials: plastic or rubber parts in prolonged skin contact should be checked against REACH Annex XVII restrictions such as those on PAHs and phthalates;
• Heat: heated lash curlers and wax warmers need surface-temperature checks, auto shut-off and warnings.

Electric beauty devices are harmonised products: generally the Low Voltage Directive (within its voltage range), EMC and RoHS apply, with CE marking and an EU declaration of conformity; wireless models add the Radio Equipment Directive, and battery models the Batteries Regulation (EU) 2023/1542. GPSR Chapter III Section 1 does not apply; the EU operator requirement comes from Article 4 of Regulation (EU) 2019/1020, while GPSR online, accident and recall rules still apply. IPL and laser devices fall under Annex XVI of the Medical Devices Regulation and the common specifications in Regulation (EU) 2022/2346 even without a medical purpose, a much higher bar. See GPSR vs CE marking.

Practical tips for Amazon EU and other marketplaces

Amazon has stated publicly that products sold in its EU stores need manufacturer details, EU Responsible Person details and safety information or warnings (which can be uploaded as images or documents), entered through Seller Central pages such as Manage Your Compliance, and that listings missing this information may be deactivated. Seller Central labels and fields change, so always follow the current pages. Temu, TikTok Shop and your own shop are bound by the same GPSR Article 19, and marketplaces must act on authority requests about dangerous products (GPSR Article 22).

For beauty listings we suggest:

• Keep the Responsible Person identical across the listing, the pack and the CPNP notification;
• Upload sharp photos of the front and back label and the ingredient list, so precautions and the batch position are easy to see;
• Provide warnings in the language of each store, e.g. German for amazon.de and French for amazon.fr;
• For perfumes, nail polish and aerosols, which are often flammable, prepare a safety data sheet (SDS) and other files for Amazon's dangerous goods (hazmat) review;
• Keep the CPSR, key PIF pages, CPNP confirmation and test reports ready to send when a platform or authority asks;
• Never use a fake EU address or "borrow" someone else's Responsible Person. The role carries real legal liability, and the consequences go far beyond a suppressed listing. If you are unsure what is missing, start with the 3-step compliance check.

If a listing has already been deactivated, work through how to restore an Amazon listing deactivated for GPSR.