The short answer
To sell a cosmetic in the EU you need: a Responsible Person established in the EU, a formula that complies with the annexes of Regulation 1223/2009, a safety report (CPSR) signed by a qualified assessor, a Product Information File (PIF), a CPNP notification and a compliant label with substantiated claims. The most expensive mistake is finding a formula or label problem after printing.
The steps, in order
1. Appoint a Responsible Person (RP) established in the EU (Art. 4 and 5). If you are outside the EU, this is often your importer or a service provider.
2. Check the formula: prohibited substances (Annex II), restricted substances (Annex III), allowed colourants, preservatives and UV filters (Annexes IV to VI).
3. Have the safety assessment (CPSR, Art. 10 and Annex I) done by a qualified assessor.
4. Build the PIF (Art. 11): description, CPSR, manufacturing method (GMP ISO 22716), proof of claimed effects.
5. Notify the product on the CPNP before placing it on the market (Art. 13).
6. Print a compliant label (Art. 19) with claims that meet Regulation 655/2013.
Where brands lose time and money
The formula is often sent to the assessor without checking Annex III restrictions or allergens. The artwork is often finalised before the file is ready. Result: back-and-forth, reprints, a delayed launch.
What this means in practice for a brand
- Get the formula checked before you order the safety assessment, so you arrive with a clean file.
- Do not print until the INCI list, mandatory mentions and claims have been checked on the real artwork.
- Selling in the UK is a separate framework (UK Cosmetics Regulation): plan it separately.
Check your formula before the safety assessment
I check your formula against the annexes of Regulation 1223/2009, allergens and your target market, and tell you what blocks before assessment, artwork and launch.
See the Formula & EU Market Fit Review — €590Formula already cleared? Get the label checked before print. Label & Claims Review — €390
Frequently asked questions
Can I sell in the EU without a Responsible Person?
No. Every cosmetic placed on the EU market needs a Responsible Person established in the EU, named on the label.
Do I need approval before selling?
No, there is no pre-market approval. But the product must be notified on the CPNP and the PIF must be ready to show to authorities.
Can Bridge & Flow act as my Responsible Person?
No. I am neither a Responsible Person nor a safety assessor. I check your formula, label and claims before those steps so they go smoothly.
Where should I start?
With the formula. If a substance is banned or over a limit, everything else (assessment, label) has to be redone.
Primary regulatory sources
Related guides
Regulatory consulting and documentation preparation — not a certification and not a regulated role. Bridge & Flow does not act as Responsible Person (Reg. 1223/2009), does not sign safety assessments, does not file notifications and is not a notified body.