FAQ’s
What is a CPSR and why do I need one?
Which products require a CPSR?
In simple terms, anything defined as a ‘cosmetic product’ needs to have a CPSR before you can sell it; this is anything that is intended to be put on the hair, skin, nails, lips, teeth, or gums to improve or change their appearance or smell is considered a cosmetic product. If you are unsure whether your product would be considered as a cosmetic, email me and I’ll let you know. See here for more details.
Do I need a cosmetic product safety report (CPSR) for every product?
By law, you must have a safety report before you can sell a cosmetic product in the EU or the UK. This applies if you have created your own recipe, or if you have used a recipe you’ve purchased from a wholesaler.
How long does a CPSR take?
How much does a CPSR cost?
The cost of a CPSR (Cosmetic Product Safety Report) in the UK varies depending on your formulation, the number of product variations, and whether you need a single CPSR, a product family CPSR, or a CPSR for specific uses (special cases). Most small businesses and indie makers search for terms like “How much is a CPSR?” or “CPSR cost UK,” and the truth is that prices can differ widely between assessors.
At General Cosmetic Safety, every quote is tailored to your exact product so you only pay for the CPSR price that matches your formula’s complexity. You’ll always receive a clear, upfront cost — no hidden fees, no unexpected add‑ons — and full support if your formulation needs adjustments before or during assessment. This means you know exactly what your cosmetic safety assessment will cost before you begin.
If you’re looking for the most accurate CPSR cost for your product type (soaps, balms, skincare, scrubs, fragrances, etc.), you can request a free, no‑obligation quote. I’ll help you understand the costs involved and what’s required to get your product fully compliant for sale in the UK (and EU, if needed).
Are all cosmetic product safety reports the same?
In short, no. All safety assessors have their own way of doing things, and use their own templates for the reports. Some assessors may offer different options, such as a very low cost option for a shorter report that is missing some information needed to comply with regulations in certain EU countries. Before you pay for a report, it is important to check that the assessor will provide everything you need to comply with the regulations of the country you are selling your product in.
The reports I provide are extremely thorough, and contain everything you need to sell your product in the UK and all EU countries.
Can I sell while I’m waiting for my CPSR?
No, you legally need a completed CPSR before any sale, including online shops, markets, and pre‑orders. But once your report is ready, you can start selling immediately (if the other requirements are met, such as the PIF, labelling and product notification to the relevant portal).
What do I need to be able to sell my cosmetic product legally in the EU/UK?
The minimum requirements for selling a product are:
1. Product Information File (PIF) held in the EU and / or UK. For information about the content of the PIF see 2015 PIF Guidance document from Cosmetics Europe. There is no central database for this, but a copy needs to be retained at an address in the EU and / or UK which is included on the label.
2. CPSR (Cosmetic Product Safety Report ie. safety assessment report)
3. Notify the EU CPNP portal and / or the UK SCPN service (UK Guidance for SCPN; user manual for EU CPNP and instruction video for CPNP)
4. Correct labelling of the product (labelling guidance from Cosmetics Europe)
Do I need additional testing before I can get a CPSR or start selling my product?
The question of whether all cosmetic products need extra testing for UK compliance, or whether all cosmetic products need microbiological, stability, or challenge testing, often comes up. What extra testing is needed?
Some cosmetic products do require additional compliance checks or laboratory tests before a CPSR can be issued and before you’re legally allowed to sell them in the UK. The exact requirements depend on your formulation, the type of product you’re making, and whether it needs specific testing such as microbiological testing, stability testing, challenge testing, or purity checks for certain raw materials.
If you’re unsure which cosmetic tests apply to your product, I’ll guide you through everything step‑by‑step. I’ll review your formulation, explain which checks are required, and—if testing is needed—refer you only to trusted UK laboratories and testing companies that I personally know and recommend.
For a clearer idea of what to prepare before requesting a CPSR, you can also read my blog on what to do before booking your cosmetic safety assessment.
What kind of stability testing do I need?
Stability observations are observations of your product’s performance over time (e.g. appearance, colour, odour, pH).
The observations should be recorded and saved in a report, which is stored in your PIF and a consideration of the stability of the product is required in the CSPR.
Do you have any older batches that have been stored / kept? For non-water containing products, for the purposes for the safety assessment, I can accept 1 month at room temperature, generally. But you should continue the observations yourself and record them in the PIF to support the shelf life of the product.
When you do stability testing, try to do it in the final packaging so that you also get information on the packaging compatibility of the product and the pack you have chosen.
Keep some samples from each batch you make, to monitor how they perform at room temperature. After a certain time period, make a note of the appearance, odour and colour and changes (if any), and this will provide evidence to support the shelf-life.
If your product contains water e.g. an oil-in-water emulsion, one way to check that the emulsion is stable is to store it at elevated temperatures (greater than 35°C) for 3 months which will give an indication of what might happen in the future, when your product might be stored for long-term at room temperature. The ability to store samples at higher temperatures is very difficult to achieve at home and therefore a specialist laboratory can be useful. If you get satisfactory stability results after 3 months you can confidently put a shelf-life of at least 12 months (and many companies use 24 months) on your product.
For further information and details, see Stability Blog and for a discussion of BBE versus PAO
The following UK-based companies carry out stability tests (and may also do other analytical testing and services such as claims substantiation / user trials etc):
Marfleet Analytical marfleetanalytical.com
If your product does not contain water: only minimal stability testing is required, such as 1 month at home, in various locations. This will give you evidence to start with a shelf life of 6 months, and as you gain more data you can extend it further.
Will I need to send you a sample of my product?
No. I’ll ask you to fill in a form that tells me what’s in your product, and how much of each ingredient there is. I’ll use this information to assess whether your product is safe and compliant with the rules in the UK and EU.
What if my recipe isn’t safe or compliant, and I need to change it?
I am often asked “can you help if my formula isn’t compliant?” While I am not a formulator, I will check your formulations for compliance against regulations and for safety thresholds; if I can tell your recipe will need adjusting from the information you provide in your quote request forms, I’ll explain why and tell you how to fix it before we move forwards with your report. If I discover that your recipe needs to be changed during the assessment, I’ll explain why and tell you how to fix it. Once you’ve adjusted your recipe, I’ll revisit your report for no extra charge.
What if I want to change a supplier in the future?
When I review a recipe I sometimes need some clues as to exactly what the ingredient is, and the supplier’s details can help with that (eg I can look on the supplier’s website, or I might have come across the ingredient from that supplier before).
If the ingredient is a mixture the supplier needs to be listed, because different suppliers can have the same product but it be composed of different ingredients, for example ‘Calendula Oil’ from Supplier A could be 10% Calendula Officinalis Extract and 90% Helianthus Annuus Seed Oil, and from Supplier B could be 8% Calendula Officinalis Extract, 91% Helianthus Annuus Seed Oil and 1% Tocopherol. All the component ingredients need to be considered in the safety assessment, and they all need to be taken into account when generating the ingredient list.
If the ingredient has a legal purity requirement, then the exact tradename and the supplier need to be listed. For example ‘Carbomer’ has a requirement for use in cosmetics ‘not allowed if contains > 0.1% benzene’. Different grades are available for different industries and therefore I check which grade you are proposing to use.
If you want to change supplier in the future for new batches: if it isn’t a mixture, and there are no legal purity requirements, you can do a swap, but you should record this in your own documentation (e.g. PIF) to show you have considered the impact, and decided that there is no difference between the version that was safety assessed, and this new version.
If it is a mixture and/or has a legal purity requirement, the safety assessment report needs to be reviewed and probably amended / updated (which will incur a fee, but a lot less than the price of a full report).
If you know that you will use different suppliers, put them all in the submission, or ask your safety assessor to only list the supplier where it is required (ie mixture or purity requirement).
Is the form complicated to fill in?
You’ll need to provide a lot of information on your forms, and some of it may seem like scientific jargon. To make the process feel less overwhelming, my forms have links to videos showing you how to fill them in, and explaining any jargon in everyday terms.
Will I understand the CPSR?
I do all the hard work of looking at the safety regulations so you don’t have to. If you have any questions once you have the report, email me and I’ll happily talk it through with you.
Why do I have to list the packaging of my product(s)? What if I want to change it in the future?
It is a requirement in the Regulations that the safety assessment needs to contain a consideration of the packaging, (in Annex 1 of the Regulation it states: “The relevant characteristics of packaging material, in particular purity and stability”).
If you want to change your packaging in the future you need to consider whether there will be an impact on the safety assessment. If the proposed change was e.g. from one type of glass bottle, to a differently shaped glass bottle, the impact would be negligible and you could record the change in your own documentation. If you are changing from one type of polymer / plastic to another, you need to have a chat with your safety assessor about what might need to be done.
What type of packaging is considered safe and compliant for cosmetic products?
Safe cosmetic packaging must meet the requirements of Regulation (EC) No 1223/2009, which states that a cosmetic product and its packaging must be safe for human health under normal or reasonably foreseeable conditions of use. This includes assessing how the packaging interacts with your formula and whether any substances could migrate into the product. Other considerations for the brand owner are whether the material meets wider chemical and environmental rules.
Because the cosmetics regulation does not set specific standardised test methods for packaging, assessors often rely on the approach used for food contact materials under Regulation (EC) No 1935/2004. Packaging materials already approved for food use are commonly considered suitable for cosmetic products with similar physico‑chemical properties, and existing migration data can support the cosmetic safety assessment.
Several horizontal regulations also apply to cosmetic packaging. Under the Packaging and Packaging Waste Directive (94/62/EC), the combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 ppm. The REACH Regulation (EC) No 1907/2006 also applies, meaning suppliers must communicate if any Substances of Very High Concern (SVHCs) are present above 0.1% w/w in a packaging component.
If your packaging uses post‑consumer recycled (PCR) plastics there may be extra checks to ensure no unwanted contaminants are present. These assessments help confirm the recycled material is still safe for use with cosmetic products. In general, I will ask that the PCR material has been approved for food contact. If it hasn’t, additional testing will be required (e.g. packaging testing at Intertek).
When reviewing your packaging, I’ll let you know what documentation is needed and whether your material is acceptable for a CPSR. If any testing or further validation is required, I can guide you through the options.
In our experience, all but the largest packaging suppliers can’t provide information on potential trace impurities, leachables, migration from the packaging etc for cosmetics. However food contact materials have had to comply with their own regulations for a long time and we consider compliance with these regulations to be sufficient for cosmetics.
What is a PIF?
What is an INCI name?
INCI stands for International Nomenclature of Cosmetic Ingredients. It is used for product labelling for the ingredient list (see INCI explanation from Personal Care Products Council for further information).
If the ingredient in a product has an INCI name available, it should be used. If the ingredient does not have an INCI name, other rules apply (please contact us if this is relevant to your product). Official INCI names are listed in the EU glossary at EU 2022 Legal Glossary but a more user-friendly searchable resource is here: CosIng database, and also indicates if the ingredient has any restrictions, but note that this database is not the official, legal source of this information – for that you should refer to the actual legislation 1223/2009 and its subsequent amendments.
What is a challenge test / preservative efficacy test (PET)?
A microbial challenge test (also known as PET – preservative efficacy test) is a specialised test where the final product is ‘challenged’ with bacteria, mould and yeast, (they are deliberately added to a sample of your product) and left for 28 days to see if anything grows. More information and details are available in a set of blogs:
Part 1
Part 2
New Guidelines
If too many bugs grow, your preservative is not suitable for the final product, and the recipe needs to be amended. A new challenge test will be required. It is also a good idea to conduct a challenge test on an aged sample.
Generally a challenge test is required when you have water in your product (there are exceptions, please contact us if you are unsure).
The following UK-based company carries out challenge tests:
What is an IFRA certificate?
An IFRA certificate is a document prepared by a fragrance compound manufacturer which lists the maximum amounts of a perfume that can be used in different product types. The safety assessor relies on the IFRA certificate to assure the safety of the perfume in the finished cosmetic product. For further details see this IFRA blog.
Can I sell cosmetic products that look like food?
Food Imitation – Products that could be confused with food:
The Regulations say that products which possess a form, odour, colour, appearance, packaging, labelling, volume or size, such that it is likely that consumers, especially children, will confuse them with foodstuffs, therefore endangering their health and safety, are prohibited.
Different competent authorities / Trading Standards may have differing opinions on how this is interpreted for actual products. If the cosmetic product is a colour and size that doesn’t look like foodstuff then it will be more acceptable. It is probably worth making some samples and checking with your local TS / competent authority.
How can I calculate essential oil / parfum allergens for ingredient lists on labels?
There are 24 allergens which are currently ‘declarable’ in the UK/ EU and must be added to the ingredient lists if above a specified level, with an additional set soon to be required in the EU (Regulation 2023/1545); deadlines for new products by 31 July 2026, and for existing products by 31 July 2028.
To work out if an allergen needs to be listed:
Obtain the allergen list of the essential oil / perfume / aroma from the supplier.
Work out how much of each allergen is in the product, taking into account the percentage of that essential oil in the product by:
Amount of allergen in final product = Amount essential oil or perfume in product (%) x Amount of allergen in the fragrance (%)/100
If the product contains more than one essential oil / perfume / aroma, sum the individual allergens which are the same across different fragrances.
If the allergen is present in the final product above 0.01% for rinse-off products or above 0.001% for leave on products, then it needs to be listed on the label.
Will ‘Brexit’ have any effect on current or future cosmetic safety assessments?
The safety assessments prepared by GCS are valid in the EU and UK. Statutory Instrument (SI) issued by UK government regarding Cosmetic Regulations post-Brexit, show the same safety requirements as the EU and significant deviation is not expected, to allow continuing cross-border selling. Some divergences are now being seen – safety assessments at GCS will consider these on a case-by-case basis. If you have an RP based in the UK, CPSRs from GCS allow products to be sold across the UK (including Northern Ireland). If you have an RP based in an EU member state, CPSRs from GCS allow products to be sold across the EU (including Northern Ireland).
The location of the the safety assessor does not have to be in the EU, but EU authorities have advised safety assessors to ensure their UK-based qualifications can be shown to be equivalent to qualifications in an EU member state, and equivalence has been confirmed for qualifications obtained in the UK by the safety assessor at GCS.
Can I use a manufactured base to make my own cosmetic products? What do I need to consider?
A number of companies make and sell a cosmetic base which brand owners can customise, in order to sell a range of products with differing scents and / or colours. A CPSR (see Get a CPSR) is required for the finished products. The supplier of the manufactured base will often provide the brand owner with the results of testing such as stability or challenge testing (where applicable), but at a minimum, needs to provide a full recipe (percentage bands are acceptable) and a list of specification tests and criteria for the base formulation.
The manufacturer may also provide manufacturing suggestions such as the maximum additions allowed, but in general an addition of up to 2% perfume / essential oil / colour is acceptable before any further testing such as stability or challenge testing is required. If other ingredients are added, the finished product variants will usually need further testing (stability or challenge testing).
Do you assess products which contain cannabidiol / CBD?
It has recently been clarified that cannabidiol derived from extract or tincture or resin of cannabis is not allowed in cosmetic products, in accordance with the Single Convention (Narcotics, natural and synthetic: All substances listed in Tables I and II of the single Convention on narcotic drugs signed in New York on 30 March 1961). CBD from other sources may be allowed and I would check the documentation related to the source of the CBD to decide if I could assess it.
Ready to reduce your cosmetic safety stress?
If you want an easier way of getting a high quality cosmetic safety assessment, you’re in the right spot. If you have your product recipe ready, click the button below to request your CPSR paperwork. But, if you have questions, use the button below to schedule a 20-minute chat and we’ll talk them through together.
Safety Assessor Qualifications
MSc (Distinction), University of Strathclyde
BSc (Hons) Chemistry, University of Nottingham
Certificate - Safety Assessment of Cosmetics in the EU, Vrije University Brussels
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