CPSR Requirements: What Documents Do You Need Alongside Your CPSR?
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Spectra Cosmetic Compliance
For the assessment process itself, see our guide to how to get a CPSR. Here we focus on the wider documentation.
A quick clarification on 'submission'
First, a point that often causes confusion: in the UK and EU, cosmetics are not submitted to an authority for pre-market approval before sale. There is no approval body reviewing a cosmetic product safety report before launch. Instead, you compile the CPSR and its supporting documents, hold them in your Product Information File (PIF), and notify the product via SCPN (Great Britain) or CPNP (EU/Northern Ireland). So "documents alongside your CPSR" means the dossier you assemble and hold not a submission pack sent off for sign off.
Understanding this shapes how you think about the paperwork, as set out under Regulation (EC) No 1223/2009 and the retained UK Cosmetics Regulation. The goal is a complete, well organised file you hold and can produce on request from the competent authorities or OPSS, not a form you submit and forget. Every document has a place in that file.
Ingredient documentation
The foundation is documentation for every one of your raw materials. For each ingredient you typically need a specification sheet, safety data sheets (SDS), and, for fragrances and essential oils, allergen declarations and IFRA certificates. Colourants, preservatives and UV filters need documentation showing they are permitted and used within limits, and some materials need a certificate of analysis or confirmation of purity criteria.
This ingredient documentation both feeds the CPSR and forms part of the file. It is often the most time consuming to gather, since it depends on your suppliers, so starting early is essential. A supplier who cannot provide proper documentation is a warning sign worth heeding before you build a product around their material.
Testing reports
Depending on the product, you will hold various testing reports: stability testing to support shelf life, a preservative efficacy (challenge) test and microbiological quality testing for water containing products, and sometimes additional data such as pH or specific safety tests. These reports underpin the assessment and evidence key aspects of the product's safety, reflecting reasonably foreseeable conditions of use. Every one of these findings feeds directly into the final safety assessment your qualified safety assessor signs off.
The qualified safety assessor advises what testing is needed, and the resulting reports become part of your documentation. Holding them in the file means that if the product's safety is ever questioned, the underlying evidence is on hand. Missing test reports are a common gap that undermines an otherwise sound file.
Manufacturing and GMP information
Your file needs a description of the manufacturing method and a statement of Good Manufacturing Practice compliance, in line with ISO 22716. If you manufacture in house, you produce this; if you use a contract manufacturer, you need to obtain it from them. This demonstrates the product is made consistently and hygienically, matching the product that was assessed and its intended use.
Brands relying on third-party manufacturers should confirm at the outset that they can access this information, as it is a required part of the PIF. A manufacturer who works with compliant brands will be familiar with the requirement and able to provide what is needed.
Labelling artwork and claims evidence
You need your finished labelling artwork, showing the ingredient list, Responsible Person details, warnings, and all mandatory information, plus evidence supporting any claims you make about the product. The label and the CPSR are linked, because the assessment specifies the warnings the label must carry, so the artwork must reflect the assessment's requirements a core part of the structure of the CPSR itself.
Claims evidence belongs in the file wherever a claim is significant enough to require substantiation. Together, the artwork and claims documentation ensure that what you tell consumers on the pack and in marketing is both compliant and supportable an area authorities and marketplaces watch closely.
Notification records
Once the product is notified via SCPN for Great Britain or CPNP for the EU you hold the notification confirmation as part of your records. Notification is a separate step from the CPSR, but the two are connected: notification draws on product information the assessment and file establish, and confirms the product can be legally placed on the market. Our SCPN vs CPNP guide explains the notification requirement.
Keeping notification records ensures you can demonstrate the product was properly notified before being placed on the market, which is itself a legal requirement. It closes the loop between assessment, file and market entry.
Bringing it together in the PIF
All of these documents come together in the Product Information File, organised around the CPSR. The PIF is the master dossier: product description, CPSR, manufacturing and GMP information, claims evidence, and animal testing data, supported by the ingredient documentation and testing reports that underpin them. A complete file is one where every piece is present and retrievable.
The practical goal is a single, well organised file per product that you can produce in full if an authority asks. Our guide to what goes into a PIF sets out the file's required structure; this article is about the supporting documents that populate and evidence it.
Why a "Complete" PIF Still Fails Without Structure
Having the right documents is only half the task; organizing them so the file actually works is the other half. A collection of correct documents scattered across inboxes, drives and suppliers is not, in any practical sense, a usable Product Information File. The goal is a single, coherent file per product where every component and supporting document is present, clearly labelled, and retrievable in moments.
This matters most at the moment it is tested when an authority asks to see the file. A well-organised file can be produced in full immediately; a disorganised one turns a routine request into a scramble, and any gap that surfaces under that pressure is a compliance problem. Investing a little structure up front a consistent folder layout, version control on documents that change, and a record of what each product's file contains pays off precisely when it matters.
For brands scaling a range, this organisational discipline is what keeps compliance manageable. Each new product gets its own complete, structured file from the outset, rather than a loose bundle assembled hastily later. The documents in this guide are the contents; a sensible system is what turns them into a file you can rely on.
Need help getting your cosmetic documentation in order?
Spectra helps brands prepare and organise the documentation needed alongside their CPSR, so every product file is complete, structured and ready when required.
Frequently asked questions
Do I submit my CPSR and documents to an authority?
No. Cosmetics aren't approved pre-market in the UK or EU. You compile the CPSR and supporting documents, hold them in your Product Information File, and notify the product. The file is produced on request, not submitted for sign off.
What ingredient documents do I need?
For each raw material, typically a specification sheet, safety data sheet, and for fragrances allergen declarations and IFRA certificates. Colourants, preservatives and UV filters need evidence they're permitted and within limits, and some materials need a certificate of analysis.
What testing reports should I hold?
Depending on the product: stability testing for shelf life, and challenge and microbiological testing for water-containing products, plus any additional data the assessor requires such as pH or specific safety tests.
Do I need manufacturing documentation?
Yes a description of the manufacturing method and a GMP statement (ISO 22716). If you use a contract manufacturer, obtain this from them, as it's a required part of the PIF.
Is labelling part of the documentation?
Yes. You hold the finished labelling artwork and evidence for any significant claims. The label must reflect the warnings the CPSR specifies, so artwork and assessment are linked.
Where do all these documents go?
Into the Product Information File, organised around the CPSR. The PIF is the master dossier you hold per product and produce on request. A complete file has every supporting document present and retrievable.
When should I gather these documents?
Early especially ingredient documentation from suppliers, which is often the slowest to obtain. Having everything ready before assessment begins keeps the whole process moving.
How should I organise all these documents?
As a single, coherent file per product every component and supporting document present, clearly labelled and retrievable in moments. A consistent folder structure and version control turn a pile of correct documents into a file you can actually produce on request.
References: Regulation (EC) No 1223/2009, Articles 10–13 (EUR-Lex); UK Cosmetics Regulation as retained; ISO 22716; OPSS guidance. General information only, not legal advice.