Three parallel mechanisms
Prohibitions and restrictions: Annex II lists more than 1,600 prohibited substances. The CPSR (Cosmetic Product Safety Report): the mandatory toxicological safety assessment. The CPNP notification: pre-market notification of every product in the EU database. All three must be in place.
Switzerland applies VKos, closely modelled on the EU regulation. The MRA contains no cosmetics chapter — addressing both markets means satisfying both systems independently.
The CPSR
The CPSR is the single most important document in cosmetics compliance. It determines whether the product is deemed safe — not the authority, not the lab. The toxicologist who signs Part B.
Part A: quantitative composition, physical and chemical properties, microbiological quality, exposure, toxicological profile of every ingredient.
Part B: the actual safety assessment — a scientifically reasoned statement that the product is safe. The qualification requirement for Part B is non-negotiable: a formal degree in pharmacy, toxicology, medicine or a comparable discipline.
A common mistake at small cosmetics brands: saving here. A CPSR costs between CHF 500 and 5,000. Very little compared with the cost of a recall or losing a key retailer listing.
CPNP and responsible person
CPNP is the EU-wide database for cosmetic products. Every product must be notified there before placing on the market. Free of charge. Formal obligation, no substantive review — but a condition of market access.
The responsible person assumes legal responsibility. For manufacturers without an EU establishment, their nomination is mandatory. Failure to nominate is an offence in its own right — independently of whether the product is itself compliant.
UFI obligation since 2022: all hazardous mixtures must be notified through the ECHA portal. The UFI number must appear on the label and SDS.
Claims regulation
655/2013 defines what may be said about a cosmetic product: truthful, evidenced, fair, not misleading. Comparative claims are particularly risky. Greenwashing claims are systematically challenged by authorities and competitors.