Cosmetics Compliance Checklist for E-Commerce Sellers
Selling cosmetics online in the EU is more regulated than most sellers realize. Whether you sell on Amazon, Allegro, eBay, Etsy, or your own Shopify store — you're subject to the same rules as physical retailers. Here's your complete compliance checklist.
Before You List a Product
✅ Responsible Person established in the EU
Every cosmetic product needs a "Responsible Person" (RP) with an EU address. If you manufacture in the EU, that's you. If you import from outside the EU, you need to either be the RP yourself or appoint one.
✅ Product Information File (PIF)
The RP must maintain a Product Information File containing: product description, manufacturing method, safety assessment, proof of claimed effects, and animal testing data.
✅ CPNP notification
Products must be notified to the Cosmetic Products Notification Portal (CPNP) before being placed on the market.
✅ Complete labeling
All 10 labeling requirements from Article 19 must be met. Missing even one element makes the product non-compliant. See our complete labeling guide.
Ongoing Compliance
✅ Safety alert monitoring
Under GPSR, you must actively monitor whether your products have been flagged in EU safety alerts. This isn't a one-time check — new alerts are published weekly.
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✅ Adverse event reporting
If you receive reports of adverse reactions from customers, you must inform the Responsible Person and the competent national authority.
✅ Product recall readiness
You must be able to recall products quickly if needed. This requires: batch number traceability, customer contact ability, and a recall procedure.
✅ Claims substantiation
Any claims on your product (anti-aging, moisturizing, etc.) must be substantiated with evidence. "Clinically proven" needs actual clinical data.
Marketplace-Specific Requirements
Amazon EU
- GPSR compliance documentation required since 2024
- Responsible Person information must be in listing
- Products can be suspended without notice for non-compliance
Allegro (Poland)
- Product safety documentation may be requested
- Consumer reports can trigger listing removal
- INCI list recommended in product description
Penalties for Non-Compliance
| Violation | Typical Consequence |
|---|---|
| Missing RP | Product withdrawal + fine |
| No CPNP notification | Fine + market ban |
| Incomplete labeling | Product withdrawal |
| Ignoring safety alerts | Fine + criminal liability |
| False claims | Fine + consumer lawsuits |
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