Cosmetics Export Compliance Testing for EU & USA

In the European Union, a cosmetic product is defined as any substance or mixture intended for external contact with the human body (epidermis, hair system, nails, lips, and external genital organs), or with teeth and oral mucous membranes. Its sole or primary purposes include cleaning, perfuming, altering appearance, protection, maintaining good condition, or improving body odor. If your product’s usage and functions fall within this definition, it will most likely be classified as a cosmetic product in the EU.

Product classification is determined by application method, scope of use, intended functions, and functional implementation approaches. For reference: items such as combs, false eyelashes, breast implants, toothbrushes, wigs, pet shampoo, and wound care products partially fit the cosmetic definition but do not meet all regulatory criteria. Such products, commonly perceived as cosmetics by the public, are not legally classified as cosmetics within the EU.

EU & USA Cosmetics Compliance testing

Step 1: Appoint an EU Responsible Person

EU Cosmetics Regulation (EC) No 1223/2009 stipulates that only cosmetics with a designated legal or natural Responsible Person (RP) established within the EU can be placed on the EU market.

Every cosmetic product sold in the EU must have a qualified EU Responsible Person, who can be a consulting firm, manufacturer, importer, or distributor.
Notably, only one single Responsible Person is permitted for the same product across the entire EU region.

Step 2: Control Product Ingredients

Before market launch, we conduct full formulation and ingredient reviews in line with EU cosmetic regulatory annex requirements.

We verify compliance with EU lists of prohibited, restricted, and permitted cosmetic substances to ensure your products fully meet regulatory restrictions and eliminate non-compliant ingredients.

Step 3: Prepare Cosmetic Product Safety Report (CPSR)

The Cosmetic Product Safety Report (CPSR) is a mandatory compliance document required under EU Regulation (EC) No 1223/2009.

Regarded as the "safety passport" for cosmetic products entering the EU market, a valid safety assessment via CPSR is a prerequisite for EU market access.

Part A: Cosmetic Safety Information (Product Safety File)

Enterprises shall provide complete product documentation, including:

1. Full formulation list: Complete INCI names, CAS numbers, and accurate percentage content of all ingredients (100% full disclosure required; confidential formula exemptions are not accepted).

2. Core test reports

• Microbiological testing

• Heavy metal testing

• Preservative efficacy challenge test

• Stability testing

3. Raw material safety documents: msds for all ingredients; IFRA certificates and 26 allergen declarations for fragrances.

4. Packaging material test reports: Safety evaluation of cosmetic packaging materials.

Part B: Cosmetic Safety Assessment (Expert Conclusion Report)

This section must be completed and signed by an EU-qualified safety assessor, covering:

• Margin of Safety (MoS) calculation

• Exposure risk assessment (inhalation risk evaluation mandatory for aerosol/spray products)

• Safety statements and usage warnings (e.g., keep away from eyes)

• Valid qualification certification of the assessor

Step 4: Compile Product Information File (PIF)

A complete Product Information File (PIF) must be compiled for each cosmetic product sold in the EU. The PIF shall be provided in electronic or paper form for official authority review at any time.
Mandatory PIF contents:

• Full product description

• Valid CPSR report

• Production process records and GMP compliance declaration

• Supporting evidence for cosmetic efficacy claims

• Information related to animal testing

Step 5: Complete CPNP Notification Before Market Launch

Last but critically important, the EU Responsible Person must submit product notification via the CPNP portal.
The Cosmetic Products Notification Portal (CPNP) is the official online notification platform established to enforce Regulation (EC) No 1223/2009 for the European Parliament and cosmetic regulatory authorities.

About JJR LAB

Equipped with professional laboratories, JJR LAB has extensive experience in cross-border testing and compliance assessment for exports to the EU, the United States and Canada. We offer one-stop cosmetic export testing services to help enterprises master international regulatory standards, meet testing requirements, and achieve smooth global market expansion.