Cosmetics × EU
Private label cosmetics for the European Union
In the EU a cosmetic needs a person before it needs a formula: a responsible person established in the Union, whose name goes on the pack and who answers for the safety file.
Private label cosmetics in Europe: the legal file behind the product
To launch private label cosmetics in Europe, you need a responsible person established in the EU, a cosmetic product safety report under Annex I of Regulation 1223/2009, a product information file kept for ten years after the last batch is placed on the market, a notification in the CPNP portal before sale, and a label that meets Article 19 in the languages required by each country of sale. A manufacturer outside the EU appoints the responsible person by written mandate, and an importer becomes the responsible person for what it places on the market unless it designates someone else.
The annexes move often. The Commission amended the rules on substances classified as carcinogenic, mutagenic or toxic for reproduction in 2025 and again in 2026, and added further restrictions in 2026. Fragrance allergen labelling has also widened: products placed on the market from 31 July 2026 must follow the extended list, and earlier ones may stay on sale until 31 July 2028.
Claims follow the common criteria in Commission Regulation 655/2013, so ‘dermatologically tested’ or ‘free from’ must be true, supported and not misleading. Animal testing of finished products and ingredients is banned, and so is marketing products tested on animals in breach of the ban. For the wider EU picture see our EU market guide, and for routes into the category see private label cosmetics. Consider this general information: in each project a qualified safety assessor and a licensed regulatory specialist review the file.
EU requirements for a private label cosmetic
Regulation 1223/2009 applies directly in every Member State. Label language is set nationally.
| Requirement | What it means | Who is responsible | Timing or cost driver |
|---|---|---|---|
| Responsible person | A legal or natural person in the EU designated for each product; without one the product cannot be placed on the market | Your EU entity, the importer, or a person appointed by written mandate | Mandate contract and the person’s own review of your file |
| Safety report | Annex I report with safety information and a safety assessment, before placing on the market | Responsible person, with a qualified safety assessor | Stability, microbiology and pack compatibility data on the final pack |
| Product information file | Description, safety report, method of manufacture with a GMP statement, claims evidence; kept for ten years after the last batch, at the address on the label | Responsible person | Document control across reformulations |
| Good manufacturing practice | Article 8 requires GMP; following EN ISO 22716 gives a presumption of conformity | Manufacturer | Audit of the contract laboratory |
| CPNP notification | One notification in the EU portal before sale, valid for all Member States | Responsible person | Per product and variant |
| Label | Responsible person’s name and address, country of origin for imports, nominal content, durability date or period after opening, precautions, batch, function, ingredients with ‘nano’ where relevant | Responsible person; distributors check the language | Language versions for each country of sale |
Annex changes come with their own transition dates. We check them for the actual formula and launch date.
Before the first EU sale
A cosmetic is ready when the file is ready, not when the stock arrives.
- Responsible person appointed in writing and named correctly on the artwork
- Final formula checked against current Annexes II to VI, including 2025 and 2026 amendments
- Fragrance allergens declared under the extended list for products placed on the market from 31 July 2026
- Product information file complete, with GMP statement and claims evidence
- CPNP notification submitted
- Label checked for Article 19 content and the language of each country of sale
Launch sequence for an EU cosmetics brand
Durations depend on the formula route and testing, so we date them once the laboratory and pack are chosen.
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1
Claim and route
Choose stock, adapted or custom formula based on what must be different about the brand.
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2
Laboratory selection
We compare selected contract laboratories on GMP evidence, documentation quality and pack minimums in our <a href="/services/private-label-manufacturing/">manufacturing stage</a>.
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3
Testing and safety report
Run stability and compatibility tests on the final pack, gather raw material data, and commission the safety assessment.
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4
Label and claims
Write the label per language and the claims file against Regulation 655/2013. Our <a href="/services/compliance-trademark/">compliance stage</a> keeps both in one review.
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5
Notify and release
Submit the CPNP notification, release the batch and keep the information file at the labelled address.
Frequently asked questions
Can a non-EU company sell private label cosmetics in the EU?
Yes, but only with a responsible person established in the EU. A non-EU manufacturer appoints that person by written mandate, or the importer takes the role. The responsible person is named on the label and answers for the safety file and the CPNP notification.
Do cosmetics need approval before sale in the EU?
No product approval is needed, but a safety report must exist and the product must be notified in the CPNP before it is placed on the market. Some ingredients, such as colourants, preservatives and UV filters, must be on the authorised lists.
How long must the product information file be kept?
For ten years after the last batch of the product was placed on the market. It must be available at the responsible person’s address on the label, in a language the national authority can readily understand.
What changed in fragrance allergen labelling in 2026?
Under Regulation 2023/1545, products placed on the market from 31 July 2026 must label the extended list of fragrance allergens above the thresholds. Products placed on the market before that date may stay available until 31 July 2028.
Have a product idea? Check it before you buy stock.
Send a short brief. We tell you what we think, including when we think you should not do it.
Tell us about your brand
A few lines are enough: what you want to sell, where and to whom. We reply with an honest view of feasibility, the stages you need and the next step.
- No obligation: the first review of your idea is free
- If we think the idea will not pay back, we say so
- Your idea stays confidential; we can sign an NDA
What happens next
- 1We review your briefand may ask a few questions
- 2A short callabout goals, budget and limits
- 3Written proposalstages, scope, fees and timing
- 4First stage startswith a decision gate at its end
- usually 300–1 000 units per product in a first order
- usually 6–12 months from brief to first sales
- EU company, contract under Polish law