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Complete Guide to EU Cosmetics Registration: Navigate Smoothly with SUNGO

In the global cosmetics trade landscape, the EU market has always occupied a core position. Its rigorous regulatory system and massive consumer base bring both opportunities and high entry barriers for brands. In 2025, EU cosmetics regulations continue to be upgraded—from adjustments to prohibited ingredients to accessible labeling. Enterprises must accurately grasp the latest requirements to achieve smooth market access.

Definition of Cosmetics

According to Regulation (EC) No 1223/2009 on Cosmetic Products, a cosmetic product is defined as: "Any substance or mixture intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, lips, and external genital organs) or with the teeth and the mucous membranes of the oral cavity, with the primary aim of cleaning them, perfuming them, changing their appearance, protecting them, maintaining them in good condition, or eliminating body odour."

Core of the Regulations

Dual Challenges: From Market Access to Compliance

Regulation (EC) No 1223/2009 is the cornerstone of market access. In 2025, multiple amendments further tighten supervision:

Strengthened Restrictions on Prohibited/Restricted Ingredients
- TPO Ban in Effect: Starting September 1, 2025, the photoinitiator (2,4,6-Trimethylbenzoyl)diphenylphosphine oxide (TPO) is fully banned. Cosmetics containing this ingredient are prohibited from entering the EU market, and existing products must be removed from shelves immediately.
- Octocrylene Restriction Proposal: France has proposed limiting the content of the sunscreen agent Octocrylene to below 0.001% (w/w) to protect soil and water environments. Currently in the public consultation phase, it is expected to take effect in 2026.
Accessible Labeling

Cosmetic labels must include key information such as ingredient lists and usage instructions, ensuring they are easily accessible and understandable to all consumers.
Strict Control of Nanomaterials

Cosmetics containing nanomaterials must be separately notified 6 months before market launch, with detailed information such as particle size and toxicological data submitted. The review period has been extended to 15 working days.

Registration Process: 5-Step Navigation to Success

Step 1: Appoint an EU Responsible Person (RP)

Non-EU enterprises must entrust a legal entity or professional institution within the EU as the RP, responsible for product compliance reviews and regulatory communication.

Step 2: Prepare a Cosmetic Product Safety Report (CPSR)

The CPSR is a core registration document, issued by a toxicologist or pharmacist, consisting of two parts:

Part A (Safety Information): Ingredient concentrations, microbiological quality, impurity assessment, exposure during use, etc.
Part B (Safety Assessment): Conclusions based on data in Part A, specifying warning statements (e.g., "Contains alcohol—keep away from fire") and usage restrictions (e.g., "Not for children").

Step 3: Complete CPNP System Filing

Product name, category (leave-on/rinse-off), country of origin, and target EU member states;
Full ingredient list (per INCI nomenclature);
High-resolution images of labels and packaging (must include EU Representative information);
Special data on nanomaterials (if applicable).

Step 4: Review

The review period is typically 5-7 working days. If information is incomplete or high-risk ingredients are present, supplementary tests (e.g., heavy metal and microbiological testing) may be required.

Step 5: Obtain CPNP Number and Market Circulation

Upon approval, the system generates a unique CPNP number. Enterprises must retain the CPNP document for inspection. This number is a key document for customs clearance and market inspections—absence or forgery will result in heavy fines.

Pitfall Avoidance Guide: Three High-Frequency Risks and Countermeasures

1. Incorrect Ingredient Use

Risk: Use of EU-prohibited/restricted ingredients (e.g., TPO, formaldehyde releasers).
Countermeasure: Establish a dynamic ingredient database, regularly cross-check with EU Cosmetics Ingredient Lists (e.g., Annexes II-V), and prioritize raw material suppliers with EC certification.

2. Labeling Violations

Risk: Missing EU Representative information, shelf life (PAO symbol), or incorrect ordering of ingredient concentrations.
Countermeasure: Adopt multilingual label templates to comply with EU language requirements (e.g., French, German).

3. Lack of Qualified Responsible Person

Risk: Failure to appoint an EU Representative or invalid RP qualifications.
Countermeasure: Select a qualified third-party institution, sign a written entrustment agreement, and clarify the division of responsibilities.

Professional Support: SUNGO’s One-Stop Compliance Services

Official CPNP Notification: Quickly complete EU cosmetics registration and seize market opportunities.
Precision Review of Formulations & Labels: Comprehensive compliance risk screening to avoid recall losses.
Authoritative CPSR: Backed by professional certification to build consumer trust.
Full-Range EU RP Agency: A statutory required role to eliminate operational worries.