The EU General Product Safety Regulation (GPSR) applies to a wide range of consumer products, including cosmetic products. However, for many product categories, the regulatory requirements have traditionally been less stringent than those applicable to cosmetics. The GPSR raises te level of product safety and compliance requirements for these product categories, bringing them largely in line with the standards that have already long been established for cosmetic products under the EU Cosmetics Regulation (EC) No 1223/2009.

The EU GPSR has limited impact on cosmetics compliance

There are additional requirements in online sales that go beyond, or further clarify, those set out in the EU Cosmetics Regulation (EC) No 1223/2009. These requirements relate specifically to the information that must be made available on the individual online product sales page before a consumer purchases the product.

The GPSR does not affect areas that are already comprehensively regulated under the Cosmetics Regulation, such as the Product Information File (PIF), ingredient restrictions, cosmetic product safety assessments, labelling requirements, product claims, CPNP notifications, and related obligations.

EU GPSR – additional requirements for cosmetics in online sales

The primary objective of the EU GPSR is to enhance product traceability, enabling market surveillance authorities to easily identify and contact the EU Responsible Person (EU RP). In addition, The GPSR aims to ensure that consumers have access to essential product safety information when purchasing products on line.

For cosmetic products sold through online channels – such as brand’s own webshop, a distributor’s webshop, or online marketplaces and retailers (e.g. Amazon, Sephora, or Douglas) – the GPSR introduces three additional information requirements that must be displayed on the individual product sales page before the purchase is completed.

1. Visibility of all safety-related information: All mandatoy safety information that appears on the packaging must also be clearly accessible to consumers on the individual online product sales page before the purchase is completed. This includes, where applicable, the ingredients list, mandatory warnings and precautions, instructions for safe use, and any other safety-related information required under the EU Cosmetics Regulation.

2. Physical address of the EU Responsible Person (RP): the physical address can be shortened and limited to the abbreviated company name, zip code and the two-letter country code. For example, when The Regulatory Company is the EU RP this is TRC 2514 AA NL

3. Electronic address of the EU Responsible Person (RP). For example, when The Regulatory Company is the EU RP this is www.theregcom.com/rp.

How to best meet these requirements?

The EU GPSR allows for all information to be communicated online by uploading up-to-date clearly legible product and/or label images on the individual product page that contain all required information.

However, it may be impractical or impossible to upload multiple and sufficiently clearly legible images on the product page in all online sales channels. Also keep in mind that the information and therefor the images have to be up-to-date at all times.

An alternative or in addition to product and/or label images is to include (part of) the stated additionally required information in editable fields on the individual product pages.

To meet these requirements, it is important to organise your images and/or your information, to place the information on the sales websites that are under your own control, and to share the information down the supply chain to other online sales channels on request.

ADVICE: To prevent unwanted phone and/or email traffic from consumers with questions about matters that have nothing to do with compliance DO NOT put physical address details, email addresses and phone numbers online. Placing email addresses online will also result in increased email spam messages.

ADVICE: When placing the additionally required information online, make clear that this information is only relevant to and to be used by EU competent member state authorities. For example, by including a statement that these Responsible Person details are “For authorities only”.

These requirements have been valid since December 13, 2024.

Conclusion / Insight

One of the objectives of the EU GPSR is to improve traceability for authorities and to ensure the communication of safety-related consumer information of products sold over the internet in the EU.

The impact for cosmetics, when product compliance and safety is currently properly managed, is limited and mostly administrative.

Companies selling cosmetics online in the EU should ensure that the additional GPSR information requirements are implemented and maintained across all relevant online sales channels.