Who Needs a CPSR, and When? Every Seller Explained

The short answer

Every cosmetic made available to anyone in Great Britain, Northern Ireland or the EU in the course of a business needs a CPSR before it goes on sale, whether you sell it, give it away as a sample or use it on clients. The Responsible Person (the brand owner, the importer, or whoever they appoint in writing) must make sure the report exists and that Part B is signed by a qualified safety assessor. Distributors and retailers do not commission their own, but they must check the labelling and must not sell a product they have reason to think is non-compliant. Products made purely for your own use, genuinely occasional private gifts, and products that are not cosmetics at all fall outside it.

Key takeaways

The trigger is supplying a cosmetic in the course of a commercial activity, paid or free. Turnover, batch size and sales channel make no difference.
Etsy, Amazon, craft fairs, salons and wholesale orders are all making a product available on the market.
Free samples, gift-with-purchase minis, testers and influencer packs need the same CPSR as the full-size product.
If your name or brand is on the label, you are the Responsible Person, even if a contract manufacturer made it.
Importers are the Responsible Person for products made outside the UK (for GB) or outside the EU (for the EU) unless they appoint someone in writing.
Distributors do not need their own CPSR, but they must verify the label and stop selling if they suspect the product is non-compliant.
A change of formula, supplier, packaging, claim or market can leave your existing CPSR out of date.

Most people who ask us "do I need a CPSR?" are hoping for a no. A soap maker with a stall at the Saturday market. A mum selling lip balms to friends of friends on Facebook. A white-label brand whose manufacturer says "don't worry, we have all the paperwork". A Shopify shop that just added an Amazon UK listing. The honest answer is almost always yes, and the useful answer is working out who has to hold the report and when it has to exist.

This guide goes through every seller and situation we are regularly asked about, with the rule behind each one. The law is Regulation (EC) No 1223/2009: the EU version applies in the EU and Northern Ireland, and the retained GB version, as amended by Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, applies in Great Britain and is enforced through the Cosmetic Products Enforcement Regulations 2013. If you need a refresher on what the report itself contains, start with what a CPSR is.

The trigger: making a cosmetic available on the market

The CPSR duty is not linked to profit, size or channel. It is linked to one legal idea. Under Article 2, "making available on the market" means any supply of a cosmetic for distribution, consumption or use in the course of a commercial activity, whether in return for payment or free of charge. "Placing on the market" is the first time that happens in a given market. Article 10 then says the Responsible Person must make sure the product has a safety assessment and a CPSR set up under Annex I before it is placed on the market. Not after the first few sales. Before.

Three things follow from that wording:

Free counts. A sample, a tester or a product used on a client is supplied just as much as one that is sold. OPSS guidance says in terms that it covers products "sold or given away (for example, free samples) and products used on the public by professionals".
Scale does not count. One unit supplied in a business context is enough.
Each market counts separately. An importer bringing in a product that has sold abroad for years is still placing it on the UK or EU market for the first time.

Who needs a CPSR: the Responsible Person in each business model

For every cosmetic there has to be a Responsible Person established in the market, and it is that person who must ensure the CPSR exists. Article 4 sets out who it is: the manufacturer (which includes a brand that has a product made and sells it under its own name), the importer, or a person either of them appoints by written mandate who accepts in writing. A distributor becomes the Responsible Person if it sells the product under its own name or trademark, or changes it in a way that could affect compliance. Here is how that plays out in practice.

Your business	Who is the Responsible Person	Who needs to have the CPSR
You make and sell your own soap, balms or skincare in the UK	You (or your company)	You
You make in the UK and also sell to EU customers	You for GB; a person established in the EU, appointed in writing, for the EU	Both of you need a report that covers each market
A contract manufacturer makes it and your brand is on the label	You, as the brand owner	You; the manufacturer's report only counts if it covers your product exactly and you hold a copy
You import finished products from outside the UK or EU	You, as the importer, unless you appoint someone in writing	The Responsible Person, against UK or EU rules
You stock or wholesale another company's branded product	The brand owner or importer	Not you; you check the label and act with due care
You put your own label on a product someone else made, or change it	You become the Responsible Person	You
You manufacture for other brands	Usually the brand, unless you agree in writing to act as Responsible Person	The brand, though they often ask you to arrange it

One detail catches out EU-facing sellers. Under the EU text of Article 4(6), translating the label of a product already on the market is expressly not treated as a modification, so translating alone does not turn a distributor into the Responsible Person. Rebranding it does. Our guide to the Responsible Person role covers the duties in more depth.

Distributors and retailers: you don't commission one, but you do check

If you run a gift shop, a salon retail shelf or an online store that stocks other brands, you are a distributor. You do not need your own CPSR. Article 6 instead requires you to act with due care and, before you sell, to verify that the label carries the Responsible Person's name and address, the batch number, the ingredient list and any warnings, that the language rules are met and that the date of minimum durability has not passed. If you consider or have reason to believe a product is not compliant, you must not sell it until it is fixed, and if it presents a risk you must tell the Responsible Person and the authorities.

In practice, sensible retailers also ask a new brand to confirm that a CPSR is in place and the product is notified. It is a two-minute email, and if the answer is vague, that vagueness is itself a reason to believe something is wrong.

When is a CPSR required? The situations people assume are exempt

Hobby sellers and small batches

There is no hobby or small-batch exemption written into the Regulation. The European Commission's Blue Guide on product rules, which GOV.UK guidance also follows, does say that, in principle, occasional supplies by hobbyists or charities are not a commercial activity, and that each case depends on how regularly you supply, what the product is and what you intend. That is a narrow gap. Once you are taking orders, running a stall, listing on Etsy or posting products for sale on Instagram, you are trading, and regulators will treat you that way. Making body butter for yourself and the odd jar for your sister is fine. Selling twenty jars a month is a business. See our guide to moving from hobby to business if you are at that point.

Free samples, gift-with-purchase and testers

Samples sent to influencers, minis dropped into orders, testers on a counter and products donated as raffle prizes by a brand all need to be covered. Usually the full-size CPSR can cover a sample of the same formula, but only if the assessment considered the sample packaging. A counter tester that dozens of people dip their fingers into also raises contamination questions the assessor should have thought about.

Craft fairs, markets and pop-ups

A product sold on a market stall needs the same CPSR, Product Information File, notification and label as one sold in a department store. Market traders are, if anything, easier to inspect. Our article on what happens in a Trading Standards inspection shows what officers ask to see.

Etsy, Amazon, eBay and your own website

Marketplaces do not take on your legal duties, and they are increasingly quick to pull cosmetic listings after a complaint or a document request. Selling online also decides which markets you are in. If your UK Etsy shop ships a bath bomb to a customer in Germany, you have made that product available in the EU, which means an EU Responsible Person, a CPNP notification and a report that covers EU rules. Our guide to marketplace compliance documents lists what each platform tends to ask for.

Salons, spas and wholesale

Supplying a business is still making available on the market. A massage oil sold to therapists, a shampoo used by a salon on its clients and soap sold wholesale to a farm shop all need a CPSR. A professional buyer may also ask for a safety data sheet for their own workplace records, but that does not replace the CPSR.

Charity sales

The Blue Guide accepts that a non-profit can be carrying out a commercial activity when it operates in a business-related context. A one-off bake-sale table is different from a charity shop selling a regular line of soaps, or a brand donating stock to be sold. If the sales are regular, or the products come from a business, treat them as needing a CPSR.

Does your product need a CPSR at all?

The CPSR applies only to cosmetics: substances or mixtures intended to be placed on the external parts of the body (skin, hair, nails, lips and external genitals) or on the teeth and the inside of the mouth, mainly to clean, perfume, change appearance, protect, keep in good condition or correct body odour. Soap, shampoo, lotions, lip balm, perfume, bath bombs, deodorant, make-up and toothpaste are cosmetics. Candles, wax melts, reed diffusers and room sprays are not, and need a different assessment, which we explain in TRA vs CPSR. Products that claim to treat a condition or kill germs may be medicines or biocides instead. If you are unsure, our guide to borderline products goes through how the line is drawn.

Who can write and sign the CPSR?

The Responsible Person usually compiles Part A, the safety information: formula, raw material data, stability, microbiology, packaging, exposure. Part B, the assessment itself, has to be carried out by someone holding a diploma or other formal qualification from a university course of theoretical and practical study in pharmacy, toxicology, medicine or a similar discipline, or a course recognised as equivalent. That requirement is in Article 10(2) of both the GB and EU versions. A maker cannot sign off their own product without that qualification, however experienced they are. More detail is in who can sign a CPSR and in our walk-throughs of Part A and Part B.

Private label, white label and contract manufacture

This is where we see the most confusion, because the business that makes the product and the business that is responsible for it are often different. Say a contract manufacturer makes a whipped body butter and you sell it under your brand. Your name is on the label, so you are the Responsible Person. The manufacturer may hold a CPSR for its base formula, and you can rely on it, but only if it covers your fragrance, your jar, your label wording, your claims and your market, and only if you have a copy in your PIF. A manufacturer who will not share the report leaves you unable to comply, so settle it in the supply contract: who commissions the CPSR, whose name appears as Responsible Person and who pays when something changes. Our guides to private and white label responsibilities and getting a CPSR when you do not hold the formula go further.

Importing cosmetics from outside the UK or EU

Bring in a finished cosmetic from the US, Korea or China and you are the importer, and therefore the Responsible Person unless you appoint someone in writing. Note that for Great Britain this includes products made in the EU: an EU-made serum arriving in GB is an import. A safety assessment written to another country's rules does not count unless it meets Annex I and Part B is signed by a suitably qualified assessor, and the ingredients must be checked against the UK or EU annexes, which differ from US and Asian lists. Most imported products need a new or supplementary assessment. See our CPSR guide for imported cosmetics.

Northern Ireland follows the EU Regulation under the Windsor Framework, and OPSS guidance says the Responsible Person for products sold there must be established in Northern Ireland or the EU. A GB-only setup does not cover it. Our guide to selling cosmetics in Northern Ireland explains the notification side.

When a CPSR you already have stops covering the product

Article 10 requires the report to be kept up to date as new information comes in. A report covers the product as it was assessed, so check it whenever any of these happens:

The formula changes, even by a percentage point or a swapped ingredient.
A raw material comes from a new supplier, especially fragrances, essential oils and botanical extracts.
You add a scent, shade or size the report does not list.
The packaging changes, for example from a pump to an open jar.
You target a new user group, such as children, or move a body product onto the face.
You make a new claim the assessor did not consider.
You start selling into a new market: EU, Northern Ireland or GB.
An annex amendment restricts an ingredient you use.
Customers report reactions the assessment did not anticipate.

Our article on CPSR renewal and updates covers how to handle each one, usually with an addendum rather than a new report.

A five-question check before you sell

Is it a cosmetic? If not, a different assessment applies.
Will anyone else receive it in a business context, paid or free? If yes, it needs a CPSR.
Is your name on the label, or are you importing it? If yes, you are the Responsible Person and the CPSR is your job.
Does an existing report cover this exact product, supplier, pack, claim and market? If not, it needs an addendum or a new report.
Are you selling in GB, the EU, Northern Ireland, or more than one? The report, the Responsible Person and the notification (SCPN for GB, CPNP for the EU and Northern Ireland) must match every market.

If your situation still does not fit neatly, book a short consultation and we will tell you exactly what applies. And if you cannot act as the Responsible Person yourself, our UK and EU Responsible Person services can take that on.

Need a CPSR before your next sale or sample? Our qualified assessors prepare CPSRs for single products and for ranges with variants, covering GB, the EU or both.

Myths we hear

I only sell a handful of products, so I am too small to need a CPSR. There is no size, unit or turnover threshold. One bar of soap sold through an Etsy shop is placed on the market.
Free samples do not count because nobody paid for them. The definition of making available covers supply free of charge in the course of a commercial activity. OPSS guidance names free samples specifically.
My manufacturer has a CPSR, so I am covered. Only if it covers your exact product, label, packaging, claims and market, and you hold a copy in your PIF. If your name is on the label, you are the Responsible Person.
A shop that stocks my products needs its own CPSR. Distributors rely on the Responsible Person's report. Their duty is to check labelling and act with due care, not to commission a second assessment.

What to do this week

Confirm the product is a cosmetic under Article 2 of Regulation 1223/2009.
Work out who the Responsible Person is for each market you sell into (GB, Northern Ireland, EU).
Gather the full formula, supplier documents, packaging details and the label artwork.
Have a qualified safety assessor complete Part B and sign the CPSR before the first sale or sample.
Notify the product on SCPN (GB) and CPNP (EU and Northern Ireland) before it is placed on the market.
Keep the CPSR in your Product Information File and review it whenever the formula, supplier, claims or market change.

Frequently asked questions

Do I need a CPSR if I only sell a few products at craft fairs?

Yes. A product sold at a craft fair or market stall is made available on the market in exactly the same way as one sold in a shop, and Trading Standards do visit markets. There is no exemption for low volume or low turnover. The only real carve-out is a genuinely occasional, non-business supply, and a regular stall where you take payment is not that.

Do I need a CPSR to sell on Etsy or Amazon?

Yes. Selling through a marketplace does not move your legal duties onto the platform. Each cosmetic you list needs a CPSR, a Responsible Person and a notification for every market you ship to, and if your UK Etsy shop ships to customers in the EU you also need an EU Responsible Person and a CPNP notification.

Do free samples and gifts need a CPSR?

Yes, when they are given away as part of a business. The legal definition of making available covers supply free of charge, and OPSS guidance names free samples. Influencer packs, minis added to orders, counter testers and raffle prizes all need to be covered by a CPSR before they go out.

I sell a white-label product made by a manufacturer. Do I need my own CPSR?

You need a CPSR that covers the product exactly as you sell it, and as the brand on the label you are the Responsible Person who must hold it. The manufacturer's report can be used if it covers your formula, fragrance, packaging, label, claims and market and you get a copy for your PIF. If they will not share it, you need a new one.

Does a distributor or retailer need its own CPSR?

No. A shop or wholesaler that sells someone else's branded cosmetic relies on the Responsible Person's report. The distributor must check the label, language and date of minimum durability, store the stock properly, and stop selling if it has reason to believe the product is not compliant. Putting its own name on the product, or changing it, makes the distributor the Responsible Person.

Do I need a CPSR for cosmetics I import?

Yes. If you bring a finished cosmetic into Great Britain from outside the UK, or into the EU from outside the EU, you are the importer and normally the Responsible Person. A safety assessment written for the US, China or another market rarely meets Annex I as it stands, so expect a new or supplementary CPSR and an ingredient check against the UK or EU annexes.

Who is allowed to sign a CPSR?

Part B, the safety assessment, must be carried out by someone with a diploma or other formal qualification from a university course in pharmacy, toxicology, medicine or a similar discipline, or a course recognised as equivalent. That is Article 10(2) of Regulation 1223/2009, in both the GB and EU versions.

When does my existing CPSR stop covering my product?

When the formula, a raw material supplier, the packaging, the intended users, the claims or the market changes, when a variant is added that the report does not list, when an annex amendment affects one of your ingredients, or when you receive reports of reactions the assessment did not anticipate. The report has to be kept up to date, so review it each time.

Official sources and legislation

#Cosmetic Compliance #CPSR #cpsr for distributors #cpsr for etsy #cpsr for gifts and samples #cpsr for handmade cosmetics #cpsr for small business #cpsr imported cosmetics #cpsr private label #do i need a cpsr #Etsy #Handmade

Written by

Syed Muhammad Shamuel Shees

Founder & Lead Compliance Consultant

Phoenix Safety Consultants is a cosmetic compliance consultancy with offices in London, Tallinn and Pensacola. Our safety assessors and toxicologists prepare CPSRs, Toxicological Risk Assessments, PIFs, SDSs and UK/EU notifications for brands of every size. Talk to the team on WhatsApp or at compliance@phoenixcosmeticsafety.com.

This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.

Who Needs a CPSR Report, and When? Every Seller and Situation Explained

The trigger: making a cosmetic available on the market

Who needs a CPSR: the Responsible Person in each business model

Distributors and retailers: you don't commission one, but you do check