EU Cosmetic Regulation for SMEs
The EU framework for placing cosmetics on the Union market centres on Regulation (EC) No 1223/2009 — Responsible Person, CPNP, safety file, labeling, and annex-driven ingredient rules.
European Commission
New ingredients, three doors: China NCI, EU annex, US substantiation
A “new INCI” is not one global project. China wants No. 59. The EU wants an annex path or a documented history. The US wants safety substantiation and a listing that matches the label.
“EU banned all fragrance allergens overnight” — debunked
2023/1545 is a labeling expansion with 2026/2028 dates. It is not a same-day ban on perfume.
EU fragrance allergen labeling: 31 July 2026 placing-on-the-market cut (Reg. 2023/1545)
From 31 July 2026, new EU placements must disclose the expanded Annex III fragrance allergens. Existing stock can sell through to 31 July 2028.
EU allergen cutover: how to split inventory so 2026 and 2028 do not get mixed
31 July 2026 is a placing-on-the-market date. 31 July 2028 is making-available. Warehouse logic has to know the difference.
EU Commission fragrance-allergen topic page: use it with 2023/1545, not instead of it
The Commission’s allergen topic page is context. The binding table is Annex III as amended by 2023/1545.
EU claims hygiene: Regulation 655/2013 still catches SME marketing first
Most SME “compliance crises” in the EU start as claims, not annex chemistry. 655/2013 is the common criteria — keep it next to the brand deck.
EU CPNP and Responsible Person: the unglamorous duties that still stop first shipments
Article 4 and Article 13 duties did not change in 2025. They still cause more failed first shipments than annex chemistry.
CosIng is a search tool: annex amendments still live on EUR-Lex
CosIng helps you find an INCI. It does not replace 1223/2009 annexes. 2025–26 is full of decks that cite CosIng as if it were the OJ.
EU CMR omnibus 2025/877: Annex II alignment applied from 1 September 2025
Commission Regulation (EU) 2025/877 bans further CLP-classified CMR substances in cosmetics from 1 September 2025. Screen INCI lists against the new Annex II entries.