Product Information File (PIF) for Beauty Products with Variations

What's included in your consolidated cosmetic PIF

Who a PIF for product variants is for

• Brands selling one formula in several shades or colours
• Makers adding different essential oils to the same base
• Private-label manufacturers producing variant collections
• Responsible Persons and importers handling variant-heavy lines
• Online sellers whose listings offer shade or scent options

Grouped variants vs separate files

What a PIF for product variants does not include

• Products with different base formulas. Each needs its own file; order them on our PIF for cosmetics page, where multi-product orders cost less per file.
• Perfumes and body mists. Fine fragrances need IFRA records and are covered by our fragrance PIF.
• Product notification. Each shade or scent is notified before sale through SCPN notification for Great Britain or CPNP notification for the EU.
• Acting as your Responsible Person. Holding the file as your legal Responsible Person is our UK Responsible Person service.
• New laboratory tests. The PIF files the test reports you already hold for the base and each variant; it does not include new lab testing.

How it works

1. Fill our Product Information Document Send the base formula with INCI percentages, each variant's colourant or essential oil, your CPSR, SDS, label artwork and test reports.
2. We confirm the grouping We check that every variant shares the base formula and flag any variant that needs its own file.
3. We check each variant Each addition is screened against Annexes II–VI, including Annex IV colourant limits and Annex III fragrance allergens.
4. We compile one PIF with a variant index Shared base records are held once and every variant is linked to its own safety, label and test data.
5. You receive your PIF Delivered as a PDF with organised folders in 72, 48 or 24 hours, depending on the delivery speed you choose.

What is a PIF for product variants?

A PIF for product variants is one consolidated Product Information File for several versions of the same cosmetic, such as a lip balm in five shades or a body oil with different essential oils, where every variant shares one base formula. Article 11 of Regulation (EC) No 1223/2009, and the same article of the UK Cosmetics Regulation, requires a PIF for every cosmetic product placed on the market, and each shade or scent counts.

That does not mean repeating the same base documents for every variant. The European Commission's Annex I guidelines (Implementing Decision 2013/674/EU) allow a combined safety report for products in the same range that differ only in colouring agent, where that difference has no impact on safety and the grouping is justified. A consolidated PIF holds the shared base records once and documents what is different about each variant, with a variant index so any shade or scent can be traced to its own data.

How to document cosmetic variants in one PIF

Which variants can share one PIF:

• Shade and colour variants: same base, different colourants. The Annex I guidelines accept a justified combined safety report where the colourant difference has no impact on safety.
• Essential-oil variants: same base, different essential oil. Each oil brings its own fragrance allergens and restricted constituents, so the Safety Assessor decides case by case and records the justification.
• Not suitable: products with a different base formula or a different product type need their own file.

What is recorded for each variant:

• Variant composition: the colourant or essential oil added and its concentration.
• Annex IV colourant check: every pigment and dye checked against its permitted use, such as colourants that must not be used in eye products.
• Fragrance allergens: Annex III allergens from the essential oil identified and declared on the label above 0.001% in leave-on or 0.01% in rinse-off products.
• Label data: shade name or code, ingredient list and allergen declarations for each variant.
• Safety outcome: the CPSR records the conclusion that applies to each variant.

Keeping a variant PIF current:

• New variants: update the variant index, CPSR and label records before a new shade or scent is sold.
• Retention: keep the file for 10 years after the last batch of each variant is placed on the market.

What we need for the base and each variant

For the base formula:

• Full formula with INCI names and percentages
• Your combined CPSR (if you do not have one yet, our multi-variant CPSR covers the base and its variants)
• Raw-material SDS, manufacturer details and GMP (ISO 22716) evidence
• Test reports you hold: stability, microbiology, challenge testing

For each variant:

• The colourant or essential oil added, with its percentage
• Supplier SDS or allergen breakdown for that addition
• Label artwork showing the shade name or code

Legal framework

• Article 11, Regulation (EC) No 1223/2009 — a PIF for every cosmetic, kept for 10 years after the last batch is placed on the market
• UK Cosmetics Regulation — Regulation (EC) No 1223/2009 as it applies in Great Britain, amended by Schedule 34 to SI 2019/696; the GB PIF must be in English
• Article 10 and Annex I — the safety assessment and CPSR inside the PIF
• Commission Implementing Decision 2013/674/EU — the Annex I guidelines, which allow a justified combined report for products differing only in colouring agent
• Annex III and Annex IV — restricted substances, including labelled fragrance allergens, and permitted colourants with their conditions of use
• Article 19 — labelling of each variant, including the ingredient list
• Article 13 — pre-market notification of each product placed on the market

Official sources:

• Implementing Decision 2013/674/EU — Annex I guidelines (EUR-Lex)
• Article 11, Product Information File — GB text (legislation.gov.uk)
• Annex IV, permitted colourants — GB text (legislation.gov.uk)
• Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)

Why brands choose Phoenix for variant PIFs

• One file for your whole range — shared base records held once, every variant indexed.
• Per-variant traceability — each shade or scent linked to its own safety, label and test data.
• £25 per extra variation — a base plus 3 variations costs £150 at Standard delivery instead of £300 as four separate files.
• 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 Delivery (72 Hours), Fast Delivery (48 Hours) or Priority Delivery (24 Hours).

Document your whole range in one PIF for product variants 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