Cosmetic Product Safety Reports (CPSR) for Beauty Products with Variations

What's included in your multi-variant CPSR

Who a multi-variant CPSR is for

• Brands selling shade or scent ranges, like lipsticks and foundations
• Private-label manufacturers producing multi-variant collections
• Responsible Persons and importers handling high-volume product lines
• Online sellers whose listings offer several shades, scents or sizes

Grouped variants vs separate reports

What a multi-variant CPSR does not include

• Variants on a different base formula. Grouping only works for variants built on the same base. If one variant does not qualify, we tell you before you pay and quote a separate assessment for it, or you can order a single-product CPSR.
• Perfumes and body mists. Fine fragrances need IFRA checks and are covered by our fragrance CPSR.
• The full Product Information File. You receive PIF-ready output and integration support; the complete dossier is a separate Product Information File service.
• Product notification and a Responsible Person. UK SCPN or EU CPNP registration and Responsible Person representation are not part of this report. See the All-in-One CPSR, PIF, SDS & UK/EU Notification bundle.

Who a multi-variant CPSR is for

1. Brands selling shade or scent ranges, like lipsticks and foundations
2. Private-label manufacturers producing multi-variant collections
3. Responsible Persons and importers handling high-volume product lines
4. Online sellers whose listings offer several shades, scents or sizes

What is a multi-variant CPSR?

A multi-variant CPSR is a single Cosmetic Product Safety Report that covers several shades, tones, finishes, scents or sizes built on the same base formula. Article 10 of Regulation (EC) No 1223/2009, and the same rule in the UK Cosmetics Regulation, requires a safety assessment and CPSR for every cosmetic before it is placed on the market. That does not always mean a separate report for every variant.

The European Commission's Annex I guidelines (Implementing Decision 2013/674/EU) allow a combined product safety report for products in the same range where the only difference is the colouring agent and that difference has no impact on safety, such as lipstick or foundation shades. The grouping must be justified, so our Safety Assessor assesses each variant and records why it belongs in the report. A lipstick in twelve shades can then be covered by one consolidated CPSR instead of twelve separate reports.

How a multi-variant CPSR groups and assesses your range

How variant grouping works:

• Shade ranges: Variants that differ only in colourant, with no impact on safety, can share one combined report under the Commission's Annex I guidelines.
• Scent and size variants: Where variants differ in fragrance or pack size, the Safety Assessor decides case by case whether one report can cover them and documents the reasoning.
• No loss of rigour: Each variant is still assessed individually. Grouping removes duplication and cost, not scrutiny.
• Confirmed before you pay: We tell you which variants qualify upfront, so there are no surprises.

What we assess for each variant:

• Per-variant toxicological evaluation: Ingredient-level safety for the base formula plus each variant's pigments, raw materials and any fragrance components, to Annex I, Part A.
• Margin of Safety (MoS) per variant: The NOAEL divided by the systemic exposure dose, following the SCCS Notes of Guidance. The Commission's guidelines state that a MoS of at least 100 is generally accepted for a substance to be considered safe in a finished product.
• Cumulative exposure assessment: Exposure from the whole formula and from substances shared across variants is taken into account.
• Ingredient and concentration checks: INCI ingredients cross-referenced against Annexes II–VI for prohibited and restricted substances.
• Annex IV colourants: Every pigment and dye checked against Annex IV, including its permitted field of application, such as restrictions on use near the eyes. This matters most for shade ranges.
• Label and claims review: Each variant's labelling checked, including shade names or codes and allergen information.

Your multi-variant CPSR deliverables in detail

Annex I, Part A — Safety Information:

• Qualitative and quantitative composition of the base formula and each variant's additions
• Physico-chemical and stability data
• Toxicological data for colourants, fragrances and active ingredients
• Exposure assessment by product type and frequency of use

Annex I, Part B — Safety Assessment:

• A qualified Safety Assessor's conclusion for each variant
• Margin of Safety calculations and justification of limits
• Risk characterisation and conditions for safe use
• A signed declaration of product compliance

Legal framework

• Regulation (EC) No 1223/2009, Article 10 and Annex I — a safety assessment and CPSR (Parts A and B) are required before a cosmetic is placed on the EU market
• Article 10(2) — the Part B assessment must be carried out by a person with a diploma in pharmacy, toxicology, medicine or a similar discipline
• UK Cosmetics Regulation — Regulation (EC) No 1223/2009 as it applies in Great Britain, amended by Schedule 34 of SI 2019/696
• Commission Implementing Decision 2013/674/EU — the Annex I guidelines, which allow a justified combined report for products differing only in colouring agent
• Annexes II–VI — prohibited and restricted substances, colourants (Annex IV), preservatives (Annex V) and UV filters (Annex VI)
• SCCS Notes of Guidance (12th Revision) — toxicological and exposure assessment methods
• Article 11 — the CPSR forms part of the Product Information File, kept for 10 years after the last batch is placed on the market

Each variant must be traceable in the PIF to its own safety data. Our report sets out variant-specific results so the whole range is ready for inspection.

Official sources:

• Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
• Implementing Decision 2013/674/EU — Annex I guidelines (EUR-Lex)
• SCCS Notes of Guidance, 12th Revision (European Commission)
• Cosmetics regulation guidance for Great Britain (GOV.UK)

Why brands choose Phoenix for multi-variant CPSRs

• One consolidated report — your whole range under a single CPSR, ready for inspection.
• Real cost saving — each extra variation adds £25 instead of a full-price report per shade or size.
• Signed by a qualified Safety Assessor — meeting the Article 10(2) qualification requirement for the UK and EU.
• Regulator-ready or we revise it free — our compliance guarantee.
• Trusted by 1,400+ brands over 14 years, including The Beard Struggle, The Essence Vault, Parfum Fabric and Junaid Jamshed.
• Fast delivery options — Standard 72 Hours, Fast 48 Hours or Priority 24 Hours.

Cover your whole range with one multi-variant CPSR today. Choose your number of variations and delivery speed above, or message us on WhatsApp on +44 7346 009332 if you are unsure which variants can be grouped.

Frequently asked questions