How to sell cosmetics online in the EU: CPNP, labels and claims

To sell cosmetics online in the EU, every product needs a responsible person established in the EU, a cosmetic product safety report and a notification in the CPNP portal, made before the product goes on sale. The label carries 7 mandatory particulars, in the language required by each country where you sell. If you resell other brands, you check the label and the date before you list them.

This guide is for beauty brands, makers of handmade cosmetics and resellers selling to consumers anywhere in the EU. The rules come from the Cosmetics Regulation (EC) No 1223/2009, which applies directly in every member state; national law adds the label language, the authority and the fines. The admin paths are from CloudCart.

What you need to sell cosmetics online

To sell cosmetics online you need a registered business, a clear role in the supply chain and the documents for every product before it appears in your store. The Cosmetics Regulation has applied since 11 July 2013 and has no lighter rules for small makers or for handmade cosmetics.

Under Article 2, a cosmetic product is a substance or mixture placed on the skin, hair, nails, lips, teeth or mouth, to clean, perfume, change the appearance, protect, keep in good condition or correct body odours.

1. Define your role. Manufacturer, importer or distributor. Your role decides who is responsible for the documents (see the table below).
2. Make sure there is a responsible person in the EU. Without one, the product cannot be placed on the market (Article 4(1)).
3. Commission the safety assessment. A qualified safety assessor carries it out, and the result is the cosmetic product safety report, or CPSR (Article 10).
4. Build the product information file (PIF). It is kept for 10 years after the last batch (Article 11).
5. Notify the product in the CPNP. Before it goes on the market (Article 13).
6. Check the label. The 7 particulars of Article 19, in the language of every country where you sell.
7. Open the store. Product pages without promises the product cannot keep (Article 20), your terms, payments and delivery.

Manufacturer, importer or distributor: what is your role?

The responsible person is a legal or natural person established in the EU who ensures the product complies with the regulation. Their name and address are on the label.

Your situation	Role under the regulation	Who is the responsible person	What you do
You make your own creams or soaps (your own brand)	Manufacturer	You (Article 4(3))	All documents: assessment, PIF, CPNP, label
A lab makes the product for you under your brand (private label)	Manufacturer (you have it made under your name, Article 2)	You, or a person in the EU with a written mandate	Agree in writing who does the assessment and the notification
You import from outside the EU	Importer	You, for each product (Article 4(5))	All documents, as a manufacturer would
You buy wholesale from an EU company and resell unchanged	Distributor	The manufacturer or the importer	The checks of Article 6 before you sell
Cosmetics dropshipping from an EU supplier	Distributor	The manufacturer or the importer	The checks of Article 6 and your liability to the customer
You sell another product under your own name, or change it	Responsible person (Article 4(6))	You	All documents

As a distributor, before you list a product you verify three things under Article 6(2): the label shows the responsible person's name and address, the batch number and the ingredient list; the language meets the rules of the country where you sell; the date of minimum durability has not passed. If you translate any element of the label yourself so you can sell in another member state, you submit data to the CPNP as a distributor (Article 13(3)).

Dropshipping cosmetics from a supplier outside the EU can make you the importer and the responsible person (Article 4(5)), so settle your role before the first sale. The model is explained in what is dropshipping.

CPNP notification: how a cosmetic product is notified

The CPNP (Cosmetic Products Notification Portal) is the European Commission's portal where the responsible person notifies every cosmetic product before it goes on the market. According to the Commission's CPNP page, notification costs nothing, and once a product is notified there, no further national notification is needed anywhere in the EU. Responsible persons, distributors, competent authorities and poison centres have access.

The notification (often searched as "CPNP registration") contains the data listed in Article 13(1):

1. Category and name of the product. So that the product can be identified precisely.
2. The responsible person. Name and the address where the product information file is kept.
3. Country of origin for imports, and the member state where the product is placed on the market.
4. A contact person. A natural person who can be reached when needed.
5. Nanomaterials. Whether the product contains substances in nanomaterial form, and their identification. These also need a separate notification under Article 16.
6. CMR substances. The name and CAS or EC number of substances classified as carcinogenic, mutagenic or toxic for reproduction, category 1A or 1B.
7. The frame formulation. For prompt medical treatment after an incident.
8. The original label and a photo of the packaging. Submitted once the product is on the market, where reasonably legible (Article 13(2)).

Cosmetic product safety report and the product information file (PIF)

The cosmetic product safety report is the document in which a qualified expert confirms that the product is safe under normal use. Without it, the product cannot be placed on the market. The assessor holds a university qualification in pharmacy, toxicology, medicine or a similar discipline (Article 10(2)).

The responsible person keeps the product information file for 10 years after the last batch is placed on the market (Article 11(1)). It contains the product description, the safety report, the manufacturing method with a statement of good manufacturing practice, proof of the claimed effect and data on animal testing.

The safety report must be kept up to date (Article 10(1)(c)), so a change of preservative or fragrance means a new review.

Cosmetics labelling requirements in the EU

The label of a cosmetic product carries 7 groups of particulars under Article 19(1), on both the container and the outer packaging, in indelible, easily legible lettering. Under Article 19(5), the language of these particulars is set by the law of each member state where the product is sold. Bulgaria, for example, requires the quantity, the date, the precautions and the function in Bulgarian. Check the rule of every country you ship to. The ingredient list stays in the common international names (INCI) everywhere.

Particular (Article 19(1))	What it says	Notes
(a) Responsible person	Name or registered name and address; for imports, the country of origin	Must be in the EU
(b) Nominal content	In grams or millilitres	Not needed below 5 g or 5 ml, or for samples
(c) Date of minimum durability	"Best used before the end of" or the hourglass symbol with month and year	Above 30 months: the period after opening (PAO) instead
(d) Precautions	The warnings from Annexes III to VI and any other precautions	Language set nationally
(e) Batch	The batch number or a reference that identifies the product	Needed for recalls
(f) Function	What the product is for, unless it is clear from its presentation	Language set nationally
(g) Ingredients	After the word "ingredients", in descending order of weight	INCI names

Expiry date for cosmetics: a date or the PAO symbol

Cosmetics that last 30 months or less carry a date. Products that last longer may have no date but carry the open jar symbol with the number of months they stay safe after opening (for example 12M). A product past its date is not sold (Article 6(2)).

INCI and fragrance allergens: the rule since 31 July 2026

INCI is the common name of each ingredient in the Commission's glossary (Article 19(6)). The perfume composition is listed as "parfum" or "aroma", while the allergens listed in Annex III are named individually. Ingredients in nanomaterial form are followed by "(nano)".

Regulation (EU) 2023/1545 adds 56 fragrance allergens that must be named individually above 0.001% in leave-on products and 0.01% in rinse-off products. According to the Commission's page on fragrance allergen labelling, since 31 July 2026 products without the new labelling may no longer be placed on the EU market. Products placed on the market before that date can still be sold until 31 July 2028. When you buy cosmetics wholesale, ask your supplier which label the batch has.

Claims: what you can write in product descriptions and ads

Every claim about a cosmetic product must be true and substantiated, on the label, on the website and in ads. Article 20 of the Cosmetics Regulation (EC) No 1223/2009 bans text, names, trade marks, pictures and other signs that imply characteristics or functions the product does not have. Regulation (EU) No 655/2013 sets 6 common criteria for every claim.

Criterion (Regulation 655/2013)	What it means for your product page	Example of a problem
Legal compliance	No "approved by" an EU authority; no presenting a legal requirement as an advantage	"Contains no banned ingredients"
Truthfulness	The ingredient you advertise is in the product; its properties do not pass automatically to the cream	"With hyaluronic acid" for a trace amount
Evidential support	The effect is backed by verifiable studies of the product	"Reduces wrinkles by 40%" without a test
Honesty	No claim of uniqueness if other products have the same property	"The only cream with vitamin C"
Fairness	No denigrating competitors or legal ingredients	"Silicones harm your skin"
Informed decision-making	Clear to the average shopper, with the conditions for the effect	The effect only works with another product, without saying so

The criteria are in Regulation (EU) No 655/2013. Two areas carry the most risk. Treatment: a promise that a cream cures a disease falls outside the definition in Article 2. And "eco": since 27 September 2026, under Directive (EU) 2024/825, a generic environmental claim such as "eco-friendly" that you cannot back with recognised excellent environmental performance, and a sustainability label that is not based on a certification scheme or set up by public authorities, are unfair commercial practices in every EU country.

Product photos and product pages for cosmetics

A cosmetics product page shows a clear photo of the packaging, the label with the ingredients and the quantity, and answers the skin type questions. A photo is a claim too: an image that suggests an effect the product does not have is banned by Article 20. A retouched before-and-after photo is the typical example.

Under Article 19 of the General Product Safety Regulation (EU) 2023/988 (GPSR), an online offer shows the manufacturer with a postal and electronic address, a photo and an identifier of the product, and the warnings. More in GPSR and the product page.

• Photos. A main photo on a light background, the back of the pack with a legible ingredient list, the texture of the product and the product in a hand for scale. How to take them with a phone and AI is in AI product photos.
• Variants. 50 ml and 100 ml, or the shades of a foundation, are variants of one product in the CloudCart catalogue, each with its own price and stock, in every plan.
• Properties and filters. Skin type, concern and active ingredient become properties in Products → Properties, and the shopper filters by them. They are in every plan, as listed on the plans page.
• Ingredients as text. An INCI list in text form is read by Google and by AI assistants, and it helps a shopper with an allergy.

Returning cosmetics: when the right of withdrawal does not apply

In every EU country, a customer has 14 days to withdraw from an online purchase of cosmetics without giving a reason, unless they have opened a sealed product that cannot be returned for health protection or hygiene reasons. The exception is in Article 16(e) of the Consumer Rights Directive 2011/83/EU. It only covers sealed goods, so the packaging needs a visible seal: film, a tamper strip or a sealed cap.

State the exception in your terms and on the product page. A faulty product or a product past its date is a claim under the legal guarantee, whatever the seal. After a serious undesirable effect, the responsible person and distributors notify the competent authority of the country where it happened without delay (Article 23 of the Cosmetics Regulation). Refund deadlines and the withdrawal form are in returns and consumer rights for online stores.

Subscriptions and repeat orders for cosmetics

Cosmetics are bought again when they run out, and a subscription is the natural model for shampoo, face cream or refills. A subscription in CloudCart creates a new order on a schedule and charges the customer's saved card, without the customer coming back to the store.

1. Install the app. Apps → Subscriptions.
2. Choose the payment method. In Apps → Subscriptions → Settings, in Payment methods, tick the method used for renewals. CloudCart Pay is included for subscriptions on every plan at no extra fee.
3. Create a plan. Set how often delivery and payment happen, for example every 30 or 60 days, and a percentage discount. The plan is linked to a product, category, collection or brand.
4. Decide what customers can do on their own. Skip a delivery, pause, cancel or change the address.
5. Switch on the reminder. The email before the renewal goes out 0 to 30 days in advance, as you choose.

Choose the interval by how long the product really lasts. More on the models in subscriptions and memberships.

Reviews for cosmetics: what the law requires and how to collect them

For cosmetics, reviews show whether a product suits skin like the buyer's. EU consumer law requires you to say whether and how you check that reviews come from people who actually bought the product, and fake reviews or edited reviews are banned as unfair commercial practices.

In CloudCart's Product Reviews app, this is set up in a few fields:

• Buyers only. In the setting for who can review, choose only customers who bought the product: a review is accepted only from a customer with a paid, completed or fulfilled order for it. Then you can say that your reviews come from verified buyers.
• Moderation. You can approve every review, or publish 4 and 5 star reviews automatically while 1 to 3 star reviews wait for approval. You cannot edit a customer's text.
• Time after purchase. From 1 to 365 days, 7 by default. For cosmetics, set at least 30, because the effect shows after weeks.

How to collect more reviews is in customer reviews for online stores.

Selling cosmetics to other EU countries: language, VAT and stores per country

One CPNP notification covers the whole EU, but three things change with every country you ship to.

• Label language. Under Article 19(5), each country sets the language of the mandatory particulars. As a distributor, a translated sticker you add yourself means a CPNP submission (Article 13(3)).
• VAT. Once your cross-border sales to consumers in other EU countries exceed €10,000 a year in total, you charge the VAT of the customer's country and declare it through the One-Stop Shop (OSS) of your own country. The details are in OSS and EU VAT for cross-border sales.
• A store per country. With the Multilang app, each language gets its own store linked to your main one: products are copied, texts can be translated with AI and prices adjusted with a multiplier. See multilingual and multi-currency stores.

Who enforces cosmetics rules and what the fines are

Each member state names its own competent authorities for cosmetics, and they see the CPNP data for market surveillance. They can order a product off the market. When a product does not comply, the responsible person withdraws or recalls it, and the distributor stops selling until the product is brought into line (Articles 5 and 6 of the regulation).

Fines are set by national law, so they differ by country. If you sell into Bulgaria, for example, the regional health inspectorates enforce the rules, and the Health Act (Article 213a) fines a company 6,000 BGN (about €3,068) for selling without a safety assessment or notification, or with a non-compliant label or claims, and 12,000 BGN (about €6,136) for a repeat offence.

Frequently asked questions

Questions about the catalogue, variants or subscriptions in CloudCart? Write to us at support@cloudcart.com. You can start your store today: Create a store for €1.