Do I Need a CPSR Before Selling Cosmetic Products, and Is It A Legal Requirement?

Key Takeaways: 

• You need a CPSR before selling cosmetics. It is legally required before any cosmetic product is placed on the market.
  
  
• Even small or handmade sellers must comply. Selling to friends, at markets, or online still counts as placing a cosmetic product on the market.
  
  
• If you’ve made a mistake, you’re not alone. Many new makers don’t realise a CPSR is required. This usually happens because people start as hobbyists or encounter misleading information online.
  
  
• Not all CPSRs are equal. Invalid or poorly prepared reports don’t count and are basically the same as having no CPSR at all.
  
  
• The legal responsibility sits with the seller. As the ‘Responsible Person’, you are accountable for ensuring your cosmetic products are safe and compliant.
  
  
• Getting a CPSR is usually simpler than people expect. With the right assessor, the process is straightforward and allows you to sell your products confidently and legally.

 

You’ve created a cosmetic product you’re proud of.

Maybe it’s a body butter you perfected after weeks of experimenting. Or a soap recipe friends keep asking you to make again. Or a balm you’ve been giving to family for months and now people are asking if they can buy it. Maybe you’ve even already started selling it, harmless as that sounds, in person and/or online.

At some point, the thought naturally appears to you:

‘Could I actually sell this?’

So you start researching what’s required.

And suddenly you’re confronted with unfamiliar terms like ‘CPSR’, ‘cosmetic safety assessment’, and ‘responsible person’.

If you’re like many of the ‘kitchen counter chemists’ I help every day, then there’s a chance your jaw has just hit the floor. Especially if you’re already selling your products. 

But don’t panic. In this article, I’m going to show you why you’re not alone, and I’m going to show you how to sell your products safely and legally without the risk of regulatory action and/or reputational damage.

Table of Contents:

1. Why you need a CPSR
2. Why people think they don’t need one
3. When to get a CPSR
4. How to get a CPSR
5. Selling without a CPSR

 

Yes, you need a CPSR before selling cosmetics & here’s why:

A CPSR is a legal requirement under UK and EU cosmetic regulations before a product can be placed on the market.

You still need a CPSR even if you are selling:

• handmade cosmetics
• small-batch products
• cosmetics at market stalls
• online from your own Facebook Marketplace shop, or anywhere
• cosmetics to friends, family and anyone close to you (yes, unfortunately, even this counts!)

If you are selling cosmetics without a CPSR, then you are not compliant with the cosmetic regulations. 

Read more: What is a Cosmetic Product Safety Report & How Do I Get One?

Contrary to what you might read or see online, CPSRs do NOT have fixed prices. These prices always come with a snag. To find out more, read our guide on CPSR costs here. 

 

 

Why many cosmetic makers don’t realise they need a CPSR:

I’ve found there are three main reasons for this:

Reason #1: Most people don’t ignore the rules; they just aren’t aware of them.

If you’re like the vast majority of customers I’ve worked with, you very likely started making your own cosmetics at home for personal use, decided to share them with your loved ones, and then decided to sell them. 

It’s easy to think nothing of it. If everyone you know loves your soaps and lotions, then what’s the harm? 

Reason #2: Sloppy misinformation from ignorant writers or AI-generated content.

Most cosmetic makers learn about the tricks of the trade from blogs and social media, and other brands. I hear inaccurate claims being made all the time, for whatever reason, such as claims that CPSRs can be added later, or are only required for large companies. 

If you read such claims, check the background of the writer (if there even is one) to see what gives them the insights to make such claims. 

Reason #3: The cosmetics industry can mislead new makers.

This third reason is what really frustrates me. I’ve worked in the cosmetics safety industry for 15+ years, and, unfortunately, there’s no shortage of cosmetic ‘regulatory’ and supply companies that:

• sell invalid or misleading safety reports
• provide reports that don’t comply with regulations
• cut corners and wouldn’t hold up under regulatory scrutiny
• advertise cheap ‘headline prices’ that aren’t real (go on, type CPSR costs into Google — I’d be willing to bet almost all of those prices are misleading)

And the most devastating part about all of this? The legal responsibility ultimately sits with the person selling the product. You are the ‘Responsible Person’. YOU would get in trouble, not them. 

True, for this reason, you probably already did your research and understood quickly that a CPSR was needed and set about trying to get one. But if your ‘CPSR’ (if we can call it that) is invalid, then it’s the same as not having one at all. 

 

When do I need to have a CPSR ready by?

You need a CPSR before placing a cosmetic product on the market. Even if you’re making a little batch of soap on your kitchen counter and selling it to a friend, a CPSR will determine if your formula is safe for others to use. 

 

How do I go about getting a CPSR?

We have a simple three-step process:

1. Submit your product details and formulations — whether you’re an indie maker, contract manufacturer or importer.
2. Our experts conduct a thorough cosmetic safety assessment to UK and EU standards.
3. Receive your bespoke cosmetic product safety assessment and launch with confidence.

We have an express service, meaning we can get your CPSR over to you in 1 working day. 

Otherwise, we normally get them over in 1-2 weeks (compared to the industry average of 6 weeks). 

We are an assessor-owned company. That means there are no third-party middlemen, which enables us to lower our costs. We offer free no-obligation quotes, and we do not charge consultancy fees. 

You can find out more and make a request on our bespoke CPSR packages page. 

 

What happens if I sell my cosmetics without a CPSR? 

If you've been selling small batches to family, friends, or on your own little business page on Facebook, then it's likely that Trading Standards will require that your products be withdrawn from sale. This would mean removing it from all online shops, market stalls, or events. 

Likewise, if you are importing or exporting without proper documents, they may be held at customs and refused entry into the country they're heading to. 

This can be a significant financial hit to some business owners, as it not only means a loss of income from the products withdrawn, but if your products end up being held at customs you’ll have to pay any storage fees. 

In fact, we once had a customer who ordered about four tonnes of body butters from China which cost £1000s and without a report for them either. Some people try to just chance it and get away with it, but in this case trading Standards stopped them at the port.

All of this could lead to reputation damage, which for small businesses and new brands can be difficult to recover from. 

But two big consequences could potentially happen depending on your circumstances.

Reason #1: You could be subjected to a regulatory investigation.

Selling a cosmetic product without a CPSR is technically a criminal offence. Without a CPSR, you have no proof that your cosmetic product is safe. The authorities would have the power to inspect your premises (even if you work from home), sample your products and demand to see your Product Information Files, which must contain your CPSR. 

Reason #2: You could be fined or imprisoned.

But the most serious consequence would be if your products are found to be unsafe or even harmful to anyone who tries them. If the case goes to court, you could be landed with an unlimited fine or even a prison sentence in addition to being banned from all marketplaces such as Etsy and Amazon.

If you had any product liability insurance, that too would be void if you were selling a product without a CPSR. 

 

We make it quick and easy to get a CPSR, so you can get on with making something you’re proud of. 

Whatever product you have and whoever you are, our 3-step process makes getting a CPSR easy. So that you can be:

• Confident in launching your cosmetic products
• Certain you aren’t breaking any regulations
• Certain you aren’t being ripped off by dodgy, other cosmetic ‘regulatory’ and supply companies
• Able to sell your products quickly with joy, without fear of legal red tape

It’s actually a very straightforward process if you work with a company that knows what it’s doing. 

Contact us today for a free, fully comprehensive, no-obligation quote and let us help you navigate the complexities of CPSR certification.

 

About the Author:

Joanne Priestley is a cosmetic safety assessor and owner of Cosmetic Safety Solutions. She has 15 years of product safety experience in the cosmetics industry. Joanne is a chartered biologist, a full member of the Royal Society Of Biology, a member of the British Toxicological Society and a passionate advocate for cosmetic safety and accurate, fair and responsible certification.

You can view Joanne's credentials here and her LinkedIn profile here.