Exporting Cosmetics to the EU: Responsible Person, CPNP, Labels

The EU Responsible Person

Only cosmetics with a Responsible Person (RP) established in the EU may be placed on the EU market; a company outside the EU cannot be the RP.

For imports the importer is the RP unless it appoints another EU-established person by written mandate. The RP's name and address go on the label, and the product file must be kept at that address.

Safety report, product file and GMP

Each product needs a Cosmetic Product Safety Report (Annex I) by an assessor qualified in pharmacy, toxicology, medicine or a similar discipline.

The RP keeps the Product Information File (PIF) for 10 years after the last batch is placed on the market: product description, safety report, manufacturing method and GMP statement, proof of claims and any animal testing data.

GMP compliance is presumed under EN ISO 22716. Selling cosmetics tested on animals to meet the Regulation is banned, fully since 11 March 2013.

CPNP notification

Before first placing a product on the market, the RP notifies it in the Cosmetic Products Notification Portal (CPNP). One notification covers the EU and is free.

It covers the product category, RP, country of origin, first Member State of sale, nanomaterials, CMR substances, frame formulation and label. Most products with nanomaterials need an extra notification six months before launch.

Label requirements

Each Member State sets the language for content, durability, precautions and function. Ingredients use the common names in the Commission's glossary (based on INCI), which are the same in every EU language.

• EU RP name and address, and country of origin for imports
• Nominal content (not needed below 5 g or 5 ml, samples or single-use packs)
• Durability date if shelf life is 30 months or less; otherwise period after opening (PAO)
• Precautions, batch number and function
• Ingredients in descending order of weight, nanomaterials marked (nano), fragrance as parfum
• Named fragrance allergens above 0.001% (leave-on) or 0.01% (rinse-off)

Banned substances, CMRs and allergens

Annex II lists banned substances and Annex III restricted ones; colorants, preservatives and UV filters must be in Annexes IV to VI. CMR substances are banned unless specifically allowed.

Omnibus VII (Regulation (EU) 2025/877) applied from 1 September 2025 and banned TPO, used in some nail products. Omnibus VIII (Regulation (EU) 2026/78) applied from 1 May 2026 with no sell-off period. Omnibus IX is in preparation for 1 February 2027.

Regulation (EU) 2026/909 bans triphenyl phosphate and limits substances such as benzyl salicylate, citral and aluminium compounds; for most, non-compliant products cannot be placed on the market from 1 January 2027.

Regulation (EU) 2023/1545 expanded the fragrance allergens that must be labelled. Products placed on the market from 31 July 2026 must comply; earlier stock may be sold until 31 July 2028.

A chemicals simplification package agreed provisionally in June 2026 changes how CMR bans are phased in; check whether it has been adopted.

Import customs: EORI, HS code, duty and VAT

The declarant, usually the EU importer or its customs broker, needs an EORI number.

Typical HS headings: 3303 (perfumes), 3304 (make-up, skin care), 3305 (hair), 3307 (deodorant, shaving, bath), 3401 (soap). Check duty and preferential rates in TARIC; preferences need proof of origin.

Import VAT is charged at the importing Member State's rate. From 1 July 2026 to 1 July 2028, B2C consignments of EUR 150 or less also pay EUR 3 duty per different item (by tariff heading).

Great Britain and staying current

EU notification does not cover Great Britain, which needs a UK-based Responsible Person and an SCPN notification to the Office for Product Safety and Standards. Northern Ireland follows EU rules.

Rules change often. This is practical guidance, not legal advice; confirm with the competent authority, your RP or a licensed customs broker or consultant.