Do I need a CPSR to sell cosmetics?

Short answer: if you sell cosmetics in the EU — even four jars of balm at a Saturday market — every product needs a safety assessment before it goes on sale. The CPSR, the Cosmetic Product Safety Report, is that assessment written down, and it lives inside your Product Information File. There is no handmade exemption. This guide is about the part most makers actually ask: who writes it, what they need from you, and what you can prepare yourself.

What a CPSR is

Annex I of Regulation (EC) No 1223/2009 splits it in two. Part A is the safety information: the full formula, the ingredient data, stability, microbiological quality, packaging, exposure. Part B is the assessment itself — a qualified assessor's reasoned conclusion that the product is safe as you make and sell it, with their signature on it.

Who is allowed to write Part B

Not most of us. Article 10(2) requires a university qualification in pharmacy, toxicology, medicine or a similar discipline. Unless you hold one, you cannot self-assess — you hire an assessor. Part A is different: it is your data, and the more of it you hand over organised, the less time the assessor bills gathering it.

What the assessor will ask you for

• The exact formula — every ingredient with its INCI name and percentage, not “a splash of” anything.
• Ingredient paperwork — supplier specifications, safety data sheets, certificates of analysis, allergen declarations for fragrances.
• Stability and compatibility — evidence the product holds up over its shelf life, in its actual packaging.
• Microbiological data — for water-containing products, usually a challenge test; anhydrous products like balms and bar soap often justify a lighter case.
• Use and exposure — what it is, where it goes on the body, how often, leave-on or rinse-off.
• The label and your claims — what the product says it does.

What this costs, honestly

Prices vary by assessor, product complexity and how ready your paperwork is — per-product fees spanning tens to a few hundred euros are common, and missing data is the usual cause of the higher end. Variants of one product (same base, different fragrance) are often assessed together for less than separate products would be.

How to make it cheap(er)

Everything in Part A rewards tidy records: exact recipes with percentages, supplier documents filed per ingredient lot, batch records that show consistency. That is bench discipline more than science — and it is the part a tool can carry for you. Alchemis keeps recipes, ingredient documentation and batch records in the shape an assessor asks for them; the assessment itself always belongs to a qualified human.

Advisory, not legal advice — and never a substitute for the assessment itself. The regulation text is public at eur-lex.europa.eu (Regulation (EC) No 1223/2009, Article 10 and Annex I).