CPSR Part A Explained: What's Inside the Cosmetic Product Safety Information

A Cosmetic Product Safety Report has two halves, and Part A is where it all begins. If Part B is the assessor's verdict, Part A is the evidence file that verdict is built on. Get Part A right and your CPSR moves quickly; get it wrong and you will face queries, delays, or a product that simply cannot be passed. This guide walks through every element of Part A in plain English, so you know exactly what your safety assessor needs and why.

Part A is defined by Annex I, Part A of Regulation (EC) No 1223/2009 (retained in UK law after Brexit). It is titled *Cosmetic Product Safety Information*, and despite the dry name it is simply a structured collection of facts about your product. If you have read our pillar guide to what a CPSR is, this article zooms in on the first half of that document and shows you how to prepare for it.

What is Part A of a CPSR?

Part A is the data-gathering section of the safety report. It pulls together everything a qualified assessor needs to evaluate your product: what is in it, how it behaves, how it is used, and what is known about the safety of each ingredient. Part A does not contain conclusions — those live in Part B. Instead, it assembles the raw material the assessor will reason from.

Think of it like a medical file before a diagnosis. The file holds the test results, the history and the measurements; the doctor's judgement comes afterwards. A thin or inaccurate file leads to a weak or impossible diagnosis. The same is true here: the quality of your Part A directly determines the quality — and the speed — of your whole CPSR. Most of the work you do as a brand owner is really about feeding Part A with accurate, complete information.

The ten elements of CPSR Part A

Annex I sets out the information Part A must contain. Here is each element, what it means, and what you typically need to supply.

1. Quantitative and qualitative composition

This is the full recipe: every ingredient identified by its correct INCI name, with the exact percentage used. The percentages must add up to 100%. This is the single most important input, and the most common source of error — wrong INCI names, missing trace ingredients, or percentages that do not reconcile will stop an assessment in its tracks. For fragrances and essential oils, the allergen content must also be declared so the assessor can check it against labelling thresholds.

2. Physical and chemical characteristics and stability

This covers what the product physically is — its form, pH, viscosity and similar properties — and evidence that it stays safe and stable over its intended shelf life. Stability data shows the product will not separate, spoil or degrade dangerously before its period-after-opening expires. Without it, the assessor cannot confirm the product will still be safe at the end of its life, not just on the day it is made.

3. Microbiological quality

This element confirms the product resists microbial contamination. For water-containing products, this is where challenge testing (preservative efficacy testing) and microbiological limits come in. Anhydrous products — oils, balms, butters — generally present lower microbiological risk and often need less evidence here, though that is a judgement for the assessor rather than an automatic exemption.

4. Impurities, traces and information about the packaging material

Raw materials sometimes carry unintended impurities or traces, and these must be considered — particularly for substances with restrictions or those that could be present as contaminants. This element also covers the packaging: the container and closure your product sits in, and whether the two interact in any way that affects safety, such as a fragrance leaching into a plastic or a product degrading a closure.

5. Normal and reasonably foreseeable use

How is the product meant to be used — and how might it predictably be misused? A lip balm will be partially ingested in small amounts; a child may get a bath product in their eyes; a face oil may be used more generously than intended. Foreseeable use shapes the exposure assumptions that follow, which is why it is treated as a formal element rather than an afterthought.

6. Exposure to the cosmetic product

This quantifies how much of the product reaches the body: the amount applied, how often, where on the body, whether it is left on or rinsed off, and the surface area involved. A leave-on face cream produces very different exposure from a rinse-off shower gel, and the assessor uses established exposure figures to model this realistically.

7. Exposure to the substances

From product exposure and the formula percentages, the assessor calculates exposure to each individual ingredient. This figure — essentially how much of each substance a real user is exposed to — feeds directly into the safety calculations performed in Part B.

8. Toxicological profile of the substances

For each ingredient, the assessor draws on the known hazard data — from scientific literature, SCCS opinions, supplier data and toxicological databases — covering effects such as skin irritation, sensitisation, and where relevant systemic toxicity. This is the safety evidence against which exposure is judged.

9. Undesirable effects and serious undesirable effects

Any record of adverse reactions linked to the product or its ingredients is captured here. For a brand-new product there may be none to report, but the element remains part of the structured file and is updated over the product's life as real-world feedback comes in.

10. Information on the cosmetic product

A catch-all for any other relevant data — existing studies, efficacy data, or additional supporting information that helps justify the product's safety. Anything that strengthens the case can sit here.

The pattern to notice: elements 1 to 5 describe the product, elements 6 and 7 calculate exposure, and elements 8 to 10 bring in the safety evidence. Together they give the assessor everything needed to reason toward a conclusion in Part B.

How Part A feeds Part B

Part A and Part B are not independent. The exposure figures from elements 6 and 7, combined with the toxicological data from element 8, are exactly what the assessor uses to calculate the Margin of Safety in Part B. In other words, the numbers you supply in Part A flow directly into the safety verdict. This is why accuracy matters so much: a wrong percentage or a missed ingredient does not just slow things down, it can change the outcome entirely. We explain the verdict side in our guide to CPSR Part B.

The most common Part A gaps that cause delays

Almost every delay we see at the assessment stage traces back to a gap in Part A. The usual culprits are:

• Incorrect or missing INCI names — trade names instead of INCI, or ingredients listed inconsistently.

• Percentages that don't total 100% — the single most frequent reason a formula is sent back.

• Missing allergen declarations for fragrance and essential oils.

• No IFRA certificate for fragrance, essential or flavour oils.

• No CI numbers for colourants, micas or glitters.

• Missing packaging details — the assessor needs to know what the product is stored in.

• No stability or challenge-test data for water-containing products.

Preparing these up front is the easiest way to keep your assessment on schedule. Our allergen compliance check can help close one of the most common gaps before you even submit.

Anhydrous vs water-containing: how Part A changes

The water content of your product reshapes Part A, especially elements 2 and 3. Anhydrous products usually need less microbiological evidence, while aqueous products require challenge testing and fuller stability data. Knowing which camp your product sits in tells you what to prepare — and helps you budget realistically before you commission the report.

A worked Part A example: a simple lip balm

To make this concrete, picture a basic anhydrous lip balm made from beeswax, shea butter, sweet almond oil, a little vitamin E and a trace of peppermint essential oil. The composition element lists each of these by INCI name with exact percentages totalling 100%. The physical characteristics and stability element describes a solid balm and shows it holds up over its shelf life without going rancid. Because there is no water, the microbiological element is light — there is little for microbes to grow in — though the assessor will still confirm that judgement rather than assume it.

The packaging element covers the twist-up tube; foreseeable use notes that a lip product is partly ingested, so exposure is calculated on that basis; and the toxicological element checks the peppermint oil and its allergen components against safe levels, drawing on the IFRA certificate you supply. Notice what is and is not needed: no challenge test, but a correct allergen declaration and IFRA documentation are essential. This is why two products that look similar on a shelf can need very different Part A evidence — the formulation, not the marketing, decides what the assessor requires.

Frequently asked questions

What is CPSR Part A?

Part A is the Cosmetic Product Safety Information section of a CPSR. It gathers all the data about a product — composition, stability, microbiological quality, exposure and toxicological profile — that a safety assessor needs before reaching a conclusion in Part B.

What information goes into Part A?

Part A contains ten elements: composition, physical/chemical characteristics and stability, microbiological quality, impurities and packaging, normal and foreseeable use, product exposure, substance exposure, toxicological profile, undesirable effects, and other product information.

Who completes Part A?

Part A is compiled from information you provide your formulation, supplier data and test results and assembled into the required format, usually by your safety assessor or compliance provider.

Why does my CPSR keep getting delayed?

The most common causes are Part A gaps: incorrect INCI names, percentages that don't total 100%, missing allergen declarations, no IFRA certificate, or absent stability and challenge-test data.

Does Part A require lab testing?

Sometimes. Water-containing products typically need challenge testing and microbiological data for Part A, while anhydrous products often need less. Stability evidence is commonly required either way.

Reference: Annex I, Part A of Regulation (EC) No 1223/2009 (EUR-Lex), as retained in UK law. General information only, not product-specific regulatory advice.