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Selling cosmetics and skincare to the EU: GPSR and the Cosmetics Regulation
By Karim El Achaq, founder of EUReady · Last updated: 6 July 2026
- Cosmetics are governed by their own EU regime, the Cosmetics Regulation (EC) 1223/2009, with the GPSR adding general listing and traceability duties on top.
- Every cosmetic needs an EU Responsible Person, a safety assessment (CPSR), and CPNP notification before it is placed on the EU market.
- Labels must carry the INCI ingredient list, nominal quantity, durability, precautions, batch number and the Responsible Person's name and address.
- The rules apply identically to natural, organic and handmade cosmetics.
Cosmetics are a special case in EU product law. Unlike candles or jewelry, they were already tightly regulated before GPSR arrived: the Cosmetics Regulation (EC) 1223/2009 governs everything from ingredient safety to labelling. The GPSR now adds general obligations around online listings and traceability on top of that regime.
The practical consequence for a Shopify skincare brand: you have two layers to satisfy. The cosmetics-specific layer (safety assessment, notification, Responsible Person, INCI list) and the general layer (complete product page information for EU buyers). Most small brands we audit are missing both.
What every cosmetics and skincare products listing must show under GPSR
Since 13 December 2024, the General Product Safety Regulation (EU) 2023/988 sets rules for products sold online to EU consumers. Article 19 is the part that hits your product pages directly: every online listing must display, before purchase, the following information.
- Manufacturer identity: the name (or trade name) of the manufacturer, a postal address and an electronic address (email). If you make the products yourself under your own brand, that is you.
- EU responsible person: if the manufacturer is not established in the EU, the name and contact details of the responsible economic operator located inside the EU.
- Product identification: enough information to identify the product, such as a picture, the product type and any batch or serial reference.
- Warnings and safety information: in a language easily understood by consumers of the country you sell to, not only in English.
The same information also has to travel with the physical product (on the item, its packaging or an accompanying document), so your labels and your Shopify pages need to match.
What are the cosmetics-specific requirements?
The Cosmetics Regulation requires four things before a cosmetic reaches the EU market: an EU Responsible Person, a signed safety report, a portal notification, and full labelling. These are separate from and stricter than the general GPSR duties.
- EU Responsible Person (cosmetics): mandatory for every cosmetic product placed on the EU market, no exceptions. This is a formal legal role defined by the Cosmetics Regulation, with duties like holding the product information file.
- Safety assessment (CPSR): each product needs a Cosmetic Product Safety Report signed by a qualified assessor before it is sold.
- CPNP notification: the product must be notified in the EU Cosmetic Products Notification Portal before being placed on the market.
- Labelling: INCI ingredient list, nominal quantity, best-before or period-after-opening, precautions for use, batch number, and the Responsible Person's name and address.
What must your cosmetics product pages show?
On the listing itself, EU buyers should be able to see the identity behind the product (manufacturer or brand with postal and electronic address), the EU Responsible Person, the ingredient list and the applicable precautions, in a language they understand. A US or UK skincare brand selling into France or Germany without any of this is the single most common non-compliant profile we scan.
Do not forget the packaging: EPR applies too
GPSR covers the product. The box, mailer, tape and filler you ship it in fall under a different set of rules: Extended Producer Responsibility (EPR) for packaging. If you ship cosmetics and skincare products to consumers in Germany you must be registered in the LUCID packaging register before your first sale, and in France you need a unique identifier via an eco-organisation such as Citeo (see our France EPR guide). Marketplaces already verify these numbers and block sellers who do not have them.
How to make your Shopify store compliant, step by step
- List what you sell to the EU. GPSR applies to new, used, repaired and handmade cosmetics and skincare products alike. There is no minimum volume: one parcel to an EU customer is enough to be in scope.
- Gather the manufacturer information. Your business name, postal address and email if you are the maker; your supplier's details if you resell.
- Appoint an EU responsible person if you are outside the EU. Authorised representative services exist from roughly 150 to 500 euros per year. Their details go on your listings and labels. Our responsible person guide explains the options.
- Write the warnings and safety information relevant to your products, and translate them for the markets you sell to.
- Add all of it to every product page. On Shopify this is usually done with metafields plus a theme block, so the information displays cleanly on each listing.
- Sort out packaging EPR for Germany and France if you ship there.
Doing this by hand across a full catalog is where most sellers give up: it is repetitive, error-prone and easy to leave half-finished. That is the exact problem EUReady automates: scan, see what is missing per product, fix it across the catalog in one click.
Check your store for free
EUReady scans every product in your Shopify store, shows you exactly what GPSR and EPR info is missing, and fills it in for you. Join the free beta and be first in line when we launch on the Shopify App Store.
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Frequently asked questions
Is the GPSR responsible person the same as the cosmetics Responsible Person?
They are different legal roles created by different regulations, but in practice one EU-based provider can usually act as both. The cosmetics Responsible Person role is older, stricter and always mandatory for cosmetics.
Do I need to notify CPNP before my first EU sale?
Yes. CPNP notification must happen before the product is placed on the EU market. It is done once per product by the Responsible Person and is free of charge.
My products are all-natural and handmade. Does that change anything?
No. The Cosmetics Regulation applies identically to natural, organic and handmade products. A soap or balm made in your kitchen needs the same safety assessment, notification and labelling as a mass-market product.
Official sources
This guide is general information for online sellers, based on publicly available EU legislation. It is not legal advice. Regulations evolve and national rules differ: for decisions that matter to your business, confirm with a qualified professional or the official sources linked above.