What You Need to Sell Cosmetics Legally (UK & EU) — Phoenix Compliance Services Skip to content
What You Need to Sell Cosmetics Legally (UK & EU)

What You Need to Sell Cosmetics Legally (UK & EU)

Turning a beautiful product into a legally sellable cosmetic takes more than a great formula and nice packaging. The UK and EU set out clear requirements every cosmetic must meet before it goes on sale and skipping them is the fastest way to lost listings, withdrawn stock or worse. This guide is your plain-English checklist of what you actually need to sell cosmetics legally.

Whether you sell on your own website, on marketplaces, or wholesale, the core compliance requirements are the same. Think of this as the map; each item links to a detailed guide if you want to go deeper.

The short answer

To sell a cosmetic legally in the UK or EU, you generally need: a safety assessment (CPSR) by a qualified assessor, a complete Product Information File (PIF), a designated Responsible Person established in your market, the product notified on the correct portal, and compliant labelling. Get those five things right and you have the backbone of a legal product; miss one and you do not.

None of these depends on how or where you sell. A hobby maker selling a few bars of soap at a market faces the same core requirements as a brand shipping thousands of units there is no small-scale exemption. The scale of the work varies with the product, but the framework does not.

1. A safety assessment (CPSR)

Every cosmetic must have a Cosmetic Product Safety Report (CPSR) a safety assessment carried out by a suitably qualified safety assessor confirming the product is safe for people to use. It draws on your full formula, ingredient data, manufacturing and intended use, and concludes whether the product can be placed on the market. Without a valid CPSR, the product simply cannot be sold legally.

This is usually the first substantive step, because so much else flows from it. Our guides explain what a CPSR is and how much it costs, but the headline is that it is non-negotiable and is the foundation of everything else.

2. A Product Information File (PIF)

Alongside the CPSR, you must hold a Product Information File — a dossier containing the product description, the CPSR, manufacturing information, proof of claimed effects, and other required details. It must be kept accessible (typically at the Responsible Person's address) and produced to authorities on request. The PIF is your evidence that the product is what you say it is and that it has been properly assessed.

The PIF is not a one off document you file and forget; it must stay current as the product changes. Our PIF guide explains what goes in it and why keeping it audit-ready matters.

3. A Responsible Person

Every cosmetic needs a designated Responsible Person (RP) the entity legally accountable for its compliance, established in the market where it is sold. For Great Britain you need a UK RP; for the EU, an EU RP. A UK maker selling at home can usually be their own RP, but selling across borders generally means appointing one in the other market.

The RP's name and address go on the label and they hold the compliance dossier. We cover the role in our guides to the Responsible Person, the UK RP and the EU RP. It is one of the most commonly missed requirements, especially after Brexit.

4. Product notification

Before a cosmetic goes on sale, it must be notified on the relevant government portal — the SCPN service for Great Britain or the CPNP portal for the EU. Notification registers basic information about the product and its RP so authorities and poison centres know it is on the market. It is not an approval, but it is mandatory, and selling an un-notified product is non-compliant.

Our guides explain SCPN, CPNP and how to notify. The key point is that notification comes before sale, not after, and applies in each market you sell in.

5. Compliant labelling

Your label must carry all the legally required information: the ingredient list in INCI, the Responsible Person's name and address, the net quantity, the durability date or PAO, any warnings, the batch code, the product function and the country of origin where relevant — all legible, indelible and in the right language. A great product with a non-compliant label is still non-compliant.

Labelling should follow the safety assessment, because the assessment determines which warnings apply. Our guides to ingredient lists and label warnings cover the detail; the point here is that the label is a legal document, not just branding.

What about testing and manufacturing?

Behind these five pillars sit good manufacturing practice and, often, some testing stability, preservative efficacy and microbiological testing, depending on the product. These feed into the CPSR rather than being separate legal boxes, but they are part of producing a safe, compliant product. Our testing guide explains what is typically needed.

Making your product hygienically, keeping batch records, and sourcing well-documented raw materials are all part of the picture too. Compliance is not only paperwork; it rests on actually making a clean, consistent, traceable product.

What happens if you skip the requirements

It is worth being clear about the stakes, because the requirements can feel like a lot when you are starting out. Selling a cosmetic without a valid CPSR, a Responsible Person, notification or compliant labelling is not a technicality it makes the product non-compliant, and the consequences are real. Authorities such as Trading Standards and the Office for Product Safety and Standards can require products to be withdrawn or recalled, and in serious cases pursue fines or prosecution.

For most small brands, though, the first painful encounter with non-compliance comes not from a regulator but from a marketplace or a customer. Listings get suspended when proof of compliance cannot be produced; stock gets stuck; a single complaint or reaction can expose a missing assessment. The commercial damage lost sales, destroyed inventory, reputational harm usually dwarfs what compliance would have cost in the first place.

Seen that way, compliance is not a tax on your business but insurance for it. The five requirements exist to ensure your products are genuinely safe and properly documented, which protects your customers and your brand alike. Getting them right from the start is far cheaper and calmer than retrofitting them after something has gone wrong.

Your sell-legally checklist

  • A valid CPSR by a qualified safety assessor.

  • A complete, accessible PIF.

  • A designated Responsible Person for each market.

  • Notification on SCPN (GB) and/or CPNP (EU).

  • Fully compliant labelling.

  • Good manufacturing practice and any needed testing.

Want everything you need to sell, in one place? Phoenix Safety Consultants provides the full compliance package CPSR, PIF, SDS, notification support and labelling so indie founders can launch legally in the UK and EU.

Get Your Compliance Package →

Frequently asked questions

What do I legally need to sell cosmetics?

A valid CPSR (safety assessment), a complete Product Information File, a designated Responsible Person in your market, notification on the correct portal (SCPN or CPNP), and compliant labelling. All are required before sale.

Is there an exemption for small or handmade brands?

No. The core requirements apply regardless of scale a hobby maker selling a few items faces the same framework as a large brand, though the amount of work varies with the product.

Do I need all this just to sell on Etsy or at a market?

Yes. The requirements depend on placing a cosmetic on the market, not on where you sell it, so the same compliance applies whether you sell online, on marketplaces or in person.

What comes first?

Usually the safety assessment (CPSR), because the PIF, labelling and notification all build on it. Labelling in particular should follow the assessment, which determines the required warnings.

Do I need a Responsible Person if I sell in both the UK and EU?

Generally yes a UK-established RP for Great Britain and an EU-established RP for the EU, since one entity rarely covers both markets after Brexit.

References: Regulation (EC) No 1223/2009 (EUR-Lex); UK Cosmetics Regulation as retained; OPSS guidance on selling cosmetics. General information only, not legal advice.

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