EU Last reviewed: 2026-08-12

EU Cosmetic Regulation for SMEs

EU cosmetics are placed on the market under Regulation (EC) No 1223/2009: a Responsible Person in the Union, a safety assessment, CPNP notification, and labels/ingredients that match the annexes.

Who should care

SME brands, importers, and Responsible Persons selling into the EU/EEA (and often Northern Ireland via the Windsor framework). Not a replacement for CPSR sign-off or national language rules.

Competent authority: European Commission; Member State competent authorities; scientific opinions via SCCS

Official sources

SME: first 5 things

  1. 1
    Appoint a Responsible Person

    Someone established in the EU must take legal responsibility before products are placed on the market.

  2. 2
    Hold a living CPSR / PIF

    Safety assessment must exist and stay current after formula, impurity, or claim changes.

  3. 3
    Notify via CPNP

    Complete notification before first placing on the market.

  4. 4
    Read annexes as living law

    Fragrance allergens, CMR omnibus, and concentration limits change by Commission regulation — not by rumour.

  5. 5
    Watch 2026–2028 label cutovers

    31 July 2026 is the placing-on-the-market date for expanded fragrance allergen labeling; sell-through runs to 31 July 2028.

Obligation map

Topic SME note Source
Responsible Person Union-established RP and PIF duties Official
Notification CPNP before placing on the market
Labeling INCI, language, allergen disclosure Official
Claims Common criteria; avoid medicinal positioning Official
Ingredients Annex II/III and CMR alignment Official

Common pitfalls

  • Treating “natural” or “clean” as a legal exemption
  • Placing on the market before CPNP is complete
  • Ignoring Member State language rules on the outer pack
  • Confusing SCCS opinions with already-binding annex text
  • Missing the 31 July 2026 allergen placing-on-the-market cut

More context

This hub is a decision map for SME brands selling into the EU/EEA. It is not a substitute for the Official Journal text, a Cosmetic Product Safety Report, or Member State enforcement practice.

What this page covers

Orientation for SME decision-makers. Confirm dates and annex entries in EUR-Lex. Great Britain is a separate regime.

Recent regulatory updates

All news

Related Insights

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Always confirm requirements against official publications before decisions.

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