CPSR Cosmetics UK: Do You Need a CPSR Before Selling Cosmetics?

If you plan to sell a cosmetic product in the UK or the EU, the short answer is almost certainly yes you need a cosmetic product safety report, and you need it before the product goes on sale, not after. This guide explains when the requirement applies, what counts as a cosmetic, who is responsible for the report, and what happens if you sell without one.

For the full picture of what a safety report is, see our pillar guide to what a CPSR is. Here we focus on whether the obligation applies to you.

UK and EU Cosmetic Regulations:

Under the UK and EU cosmetic regulations, every cosmetic product placed on the market must have a valid CPSR held on file beforehand. There is no minimum batch size, no exemption for small businesses, and no grace period for new brands. Whether you are a global manufacturer or an individual selling handmade products online, the same rule applies: no compliant cosmetic product safety assessment, no legal sale.

This surprises many new sellers, who assume that safety reports are only for large companies or that natural or handmade products are somehow exempt. They are not. The obligation attaches to the product, not to the size or nature of the business behind it.

What counts as a cosmetic

The requirement hinges on whether your product is a cosmetic in the regulatory sense. A cosmetic is any substance or mixture intended to be placed in contact with the external parts of the body skin, hair, nails, lips or with the teeth and mucous membranes of the mouth, with the purpose of cleaning, perfuming, changing appearance, protecting, keeping in good condition, or correcting body odours.

That definition is broad. It captures skincare, haircare, colour cosmetics, soaps, bath products, perfumes, toothpaste, deodorant and much more. If your product is applied to the body for one of those purposes, it is a cosmetic and needs a CPSR. Products that make medicinal or other claims may fall outside the cosmetic category and into stricter regimes but that is a reason for more regulation, not less.

Where you sell determines which regime applies

The CPSR requirement exists in both Great Britain and the EU, but they are now separate regimes. If you sell in Great Britain, you comply with the UK Cosmetics Regulation and notify via the UK's SCPN portal. If you sell in the EU, you comply with Regulation (EC) No 1223/2009 and notify via the CPNP. Northern Ireland follows the EU rules under the Windsor Framework.

A brand selling in both markets needs to satisfy both regimes. In practice the underlying safety science is the same, so a single assessment can often support both markets, but the notification, the Responsible Person and certain details differ. Our guide to SCPN vs CPNP explains the notification side.

Who is responsible for having the CPSR

The legal duty to ensure a CPSR exists falls on the Responsible Person a specifically defined role in the regulation. For a brand manufacturing or own-branding a product, the Responsible Person is usually the business itself or a designated party established in the market of sale. The Responsible Person must ensure the CPSR is completed, held in the Product Information File, and kept up to date.

This means the responsibility for the CPSR is not something you can wholly outsource away. You can and usually should engage a qualified safety assessor to produce the report, but the accountability for having a valid one rests with the Responsible Person. Understanding who plays that role in your setup is essential; our Responsible Person guide covers it.

Common situations where people wrongly assume they are exempt

A few scenarios repeatedly cause confusion. Handmade and small-batch producers often assume the rules do not apply at their scale they do. Natural or organic brands sometimes believe natural ingredients are automatically safe and exempt they are not; natural substances are assessed like any other. Selling only online or only through marketplaces does not remove the requirement either the product is still being placed on the market.

Private-label and white-label sellers are another common case: buying a pre-made base and branding it as your own generally makes you the Responsible Person, with the CPSR obligations that follow. And samples and free gifts are still cosmetics placed on the market. When in doubt, assume the requirement applies and confirm rather than assume an exemption that rarely exists.

What happens if you sell without a CPSR

Selling a cosmetic without a valid CPSR is a breach of the regulation, and the consequences are real. Market surveillance authorities the OPSS and Trading Standards in the UK, national competent authorities in the EU can require products to be withdrawn or recalled, issue enforcement notices, and in serious cases pursue penalties. Marketplaces increasingly ask for compliance documentation and can remove non-compliant listings.

Beyond enforcement, there is liability exposure. If a product without a proper safety assessment causes harm, the absence of a CPSR is a serious aggravating factor. And there is reputational risk: a compliance failure or recall can damage a brand far more than the cost of doing the assessment properly in the first place. The CPSR is cheap insurance against expensive problems.

When to get it: before you sell

The CPSR must be in place before the product is placed on the market not compiled retrospectively once sales begin or once an authority asks. Building the assessment into your product-development timeline, rather than treating it as a last-minute hurdle, is the sensible approach. It also often improves the product, since the assessment can surface formulation or stability issues before launch rather than after.

Practically, this means engaging an assessor once your formulation is finalised and your supporting data is being gathered. Our guide to how to get a CPSR walks through the process and what you will need to provide.

The cost of compliance versus the cost of getting it wrong

Brands sometimes hesitate at the cost of a cosmetic safety assessment, particularly at launch when budgets are tight. But this is the wrong comparison. The cost of a safety assessment is modest set against the cost of getting it wrong: a product recall, an enforcement notice, removed marketplace listings, or worst of all a product that harms someone and a business with no safety assessment to stand behind it.

There is also an opportunity cost to non-compliance. Increasingly, marketplaces, retailers and distributors require proof of compliance before they will stock or list a product. A missing or invalid CPSR can therefore block routes to market entirely, not just expose a brand to enforcement. In that sense the CPSR is not merely a legal hurdle but a commercial enabler the document that unlocks legitimate sales channels.

Viewed this way, the CPSR is one of the highest-value investments a cosmetic brand makes. It protects customers, protects the business, and opens doors. Treating it as an essential foundation rather than a grudging expense is the mindset that serves brands best as they grow, whether selling in the UK and EU or beyond.

Do you need a CPSR? Quick check

Not sure where you stand? Spectra can confirm whether your product needs a CPSR, clarify who the Responsible Person is, and produce safety assessments for the UK and EU markets.

Frequently asked questions

References: Regulation (EC) No 1223/2009, Articles 3–5 and 10 (EUR-Lex); UK Cosmetics Regulation as retained (legislation.gov.uk); OPSS guidance. General information only, not legal advice.