Does GPSR apply to cosmetics? It is a question many beauty brands ask as they review their EU product compliance obligations. The confusion is understandable. The EU General Product Safety Regulation, or GPSR, applies broadly to consumer products and introduces requirements around product safety, documentation, traceability, online sales and post-market responsibilities. At the same time, cosmetic products already have a dedicated legal framework under Regulation (EC) No 1223/2009 on cosmetic products, commonly known as the EU Cosmetics Regulation.
So, does a cosmetic product need to comply with GPSR, the Cosmetics Regulation, or both?
The answer depends on the specific requirements and safety risks being considered. The GPSR is a general product safety framework and is intended to work alongside sector-specific EU legislation. Where specific EU legislation already covers the safety of a product, the GPSR applies only to aspects or risks that are not covered by those specific requirements.
For cosmetic brands, this means GPSR should not simply be treated as an additional checklist that replaces existing cosmetic compliance requirements. Instead, businesses need to understand how the two frameworks interact and determine which obligations apply to their products.
This distinction becomes particularly important for brands that sell cosmetics alongside accessories, homecare products, consumer goods or other product categories. A clear regulatory assessment can help businesses avoid unnecessary duplication while ensuring that applicable safety and market access requirements are addressed.
Reviewed by Deepa Sinha – Co-founder and CTO at GCRS Group
Key Takeaways
- The EU General Product Safety Regulation, or GPSR, is designed as a general safety framework for consumer products.
- Cosmetics are primarily regulated under the specific EU Cosmetics Regulation, Regulation (EC) No 1223/2009.
- GPSR does not simply replace or override the Cosmetics Regulation.
- Where specific EU legislation already regulates the safety of a product, GPSR applies only to aspects or risks that are not covered by those specific requirements.
- Cosmetic brands should therefore assess their obligations based on the product, the applicable legislation and the specific safety risks involved.
- Businesses selling both cosmetics and other consumer products may need different compliance processes for different product categories.
- A structured compliance system can help brands identify which regulatory requirements apply to each product and market.
What Is the GPSR?
The General Product Safety Regulation, Regulation (EU) 2023/988, establishes general rules for the safety of consumer products placed or made available on the EU market.
It became applicable on 13 December 2024, replacing the former General Product Safety Directive.
The GPSR is intended to provide a safety framework for consumer products, particularly where specific EU legislation does not already regulate the relevant safety requirements.
It also introduced or strengthened requirements covering areas such as:
- Product safety assessments
- Technical documentation
- Traceability
- Consumer safety information
- Online sales
- Distance selling
- Accident reporting
- Product recalls
- Market surveillance
- Safety Gate notifications
- Responsibilities of economic operators
- Certain obligations for online marketplaces
The important point is that “general” does not mean “every product is automatically regulated by GPSR in exactly the same way.”
The Regulation itself establishes how it interacts with specific EU product legislation.
What Regulates Cosmetics in the EU?
Cosmetic products placed on the EU market are primarily regulated by Regulation (EC) No 1223/2009 on cosmetic products.
This is a dedicated regulatory framework covering the safety and compliance of cosmetic products.
It establishes requirements relating to areas including:
- Cosmetic product safety
- Safety assessments
- Product information files
- Responsible Person obligations
- Ingredient restrictions
- Labelling
- Nanomaterials
- Good manufacturing practice
- Serious undesirable effects
- Product notification
- Market surveillance
The EU Cosmetics Regulation is therefore not simply another example of a product that needs to rely on the general GPSR framework.
It provides sector-specific requirements designed specifically for cosmetics.
So, Does GPSR Apply to Cosmetics?
The practical answer is:
Cosmetics are primarily governed by the EU Cosmetics Regulation, and GPSR does not replace those specific cosmetic safety requirements.
Article 2 of the GPSR establishes that where products are subject to specific EU safety provisions, the GPSR applies only to aspects, risks or categories of risks that are not already covered by those specific requirements.
This means brands should not assume that every GPSR requirement automatically applies to a cosmetic product simply because the product is sold to consumers.
At the same time, businesses should not interpret the existence of the Cosmetics Regulation as meaning that they can ignore the GPSR completely without assessing the relationship between the two frameworks.
The correct approach is to determine which legislation governs the particular product and which safety aspects are already covered.
Why Is the Confusion So Common?
The confusion largely comes from the word “general.”
The GPSR is a general product safety framework, but it is not intended to operate as a standalone replacement for sector-specific legislation.
For example, a brand selling a face cream and a cosmetic storage accessory may need to consider different regulatory frameworks for those products.
The cosmetic product itself is primarily governed by the Cosmetics Regulation.
The accessory may fall within the GPSR framework if no more specific EU product safety legislation applies.
This is why a product-by-product compliance assessment is important.
A company should not assume that its entire product portfolio falls under one safety regulation simply because the products are sold through the same website, marketplace or retail channel.
GPSR vs EU Cosmetics Regulation
| Area | GPSR | EU Cosmetics Regulation |
| Main purpose | General consumer product safety | Specific safety and compliance requirements for cosmetics |
| Regulation | Regulation (EU) 2023/988 | Regulation (EC) No 1223/2009 |
| Primary scope | Consumer products where specific EU safety rules do not cover the relevant aspects | Cosmetic products |
| Safety requirements | General product safety framework | Cosmetic-specific safety requirements |
| Product safety assessment | Relevant where GPSR applies | Cosmetic safety assessment required under the Cosmetics Regulation |
| Product documentation | Technical documentation where applicable | Product Information File and Cosmetic Product Safety Report |
| EU Responsible Person | Relevant economic operator requirements under applicable rules | Cosmetic Responsible Person required |
| Product notification | GPSR obligations where applicable | CPNP notification for cosmetics |
| Serious safety issues | GPSR reporting and corrective action requirements where applicable | Serious undesirable effect and other cosmetic-specific obligations |
| Market surveillance | GPSR framework | Cosmetics market surveillance under applicable EU rules |
The key takeaway is that GPSR and cosmetics compliance should not be treated as interchangeable systems.
What Does the Cosmetics Regulation Already Cover?
The EU Cosmetics Regulation contains detailed safety requirements specifically designed for cosmetic products.
For example, before a cosmetic product is placed on the EU market, the responsible business must ensure that the product has undergone the required safety assessment and that the relevant product information is maintained.
The framework also establishes requirements around:
Cosmetic Product Safety Report
The Cosmetic Product Safety Report provides the safety assessment for the finished cosmetic product.
Product Information File
The Product Information File contains key compliance information and must be maintained by the Responsible Person.
Responsible Person
Every cosmetic product placed on the EU market must have an EU-established Responsible Person responsible for specific regulatory obligations.
CPNP Notification
Cosmetic products must be notified through the Cosmetic Products Notification Portal before being placed on the EU market.
Ingredient Compliance
The Cosmetics Regulation establishes restrictions and conditions for substances used in cosmetic products, including prohibited and restricted substances, colourants, preservatives and UV filters.
Serious Undesirable Effects
Cosmetic businesses must have processes for managing serious undesirable effects associated with their products.
These requirements are specific to cosmetics and cannot simply be replaced with a generic GPSR compliance checklist.
What About Product Safety Risks Not Covered by Cosmetics Legislation?
This is where the interaction between the two frameworks becomes important.
The GPSR is designed to operate as a general safety framework where specific EU legislation does not cover the relevant safety aspect or risk.
Therefore, businesses should assess whether a particular risk is already addressed by the applicable cosmetic legislation or whether another legal framework may be relevant.
For brands, this means the question should not simply be:
“Is my product a cosmetic?”
A better question is:
“Which legal requirements apply to this product and which safety risks do those requirements cover?”
This approach becomes particularly important for products that combine cosmetic and non-cosmetic characteristics, accessories, kits, packaging elements or products with multiple intended uses.
What About Cosmetic Packaging and Accessories?
Another common source of confusion is the assumption that everything sold alongside a cosmetic product automatically falls under the same regulation.
That is not necessarily the case.
For example, the cosmetic formulation and a separate reusable applicator may have different regulatory considerations depending on the product’s intended use, classification and applicable legislation.
Similarly, a cosmetic gift set can contain multiple products or components that need to be assessed individually.
Brands should therefore avoid applying one generic compliance checklist across an entire product range without first confirming the regulatory classification of each component.
Does GPSR Matter for Online Cosmetic Sales?
Online selling has made the relationship between product regulations even more important.
The GPSR introduced specific requirements concerning products offered to consumers through distance sales and online marketplaces.
However, brands selling cosmetics online still need to comply with the applicable cosmetic requirements.
This means an online cosmetic listing should not be treated as compliant simply because the business has completed a GPSR checklist.
The product may still require:
- An appropriate EU Responsible Person
- Cosmetic Product Safety Report
- Product Information File
- CPNP notification
- Compliant cosmetic labelling
- Ingredient compliance
- Appropriate claims
- Serious undesirable effect procedures
- Post-market monitoring
For businesses selling multiple product categories online, separating these regulatory workflows can help prevent gaps.
Does a Cosmetic Brand Need GPSR Compliance Documentation?
This depends on the specific product and the requirements that apply to it.
A cosmetic brand should not automatically create a GPSR technical file for every cosmetic product simply because GPSR exists.
Instead, the business should first determine:
- How the product is classified.
- Which specific EU legislation applies.
- Which safety risks are covered by that legislation.
- Whether any relevant risks or product characteristics fall outside that specific framework.
- Whether other EU legislation creates additional obligations.
This is particularly important for brands with diversified portfolios.
A company selling cosmetics, homecare products, accessories and consumer goods may need a combination of regulatory frameworks rather than one universal compliance process.
What Should Brands Do If They Sell Cosmetics and General Consumer Products?
The safest practical approach is to build a product-specific regulatory matrix.
For each product, identify:
| Question | What to Assess |
| What is the product? | Cosmetic, accessory, consumer product or another category |
| Where is it sold? | EU market, online, marketplace, retail |
| What legislation applies? | Cosmetics Regulation, GPSR or other sector-specific legislation |
| What safety requirements apply? | Product-specific and general safety requirements |
| Who is responsible? | Manufacturer, importer, Responsible Person or other economic operator |
| What documentation is required? | PIF, CPSR, technical documentation or other records |
| What market access action is required? | CPNP notification or other applicable requirements |
| What post-market controls are needed? | Complaints, incidents, recalls, SUEs or other reporting |
This approach creates a clearer compliance structure and reduces the risk of applying the wrong requirements to the wrong product.
How Compliance Automation Can Help
Managing different regulations manually becomes increasingly difficult as a product portfolio expands.
A spreadsheet may be enough for a small number of products, but larger businesses often need better visibility across products, markets, documents, owners and regulatory deadlines.
Compliance automation can help businesses create a more structured compliance workflow.
Depending on the system, it can help teams:
- Map products against applicable regulations
- Track required documentation
- Monitor regulatory changes
- Manage product information
- Maintain version control
- Track compliance gaps
- Assign actions to responsible teams
- Support audit preparation
- Maintain clearer records across multiple markets
Automation does not determine the legal classification of a product by itself. Regulatory expertise is still required.
However, a structured digital system can make it easier to manage the resulting compliance requirements once the applicable framework has been established.
Common Mistakes Brands Make
Mistake 1: Assuming GPSR Applies to Every Consumer Product
The term “general product safety” can make businesses assume that GPSR automatically applies to every product sold to consumers.
The Regulation itself provides for interaction with specific EU safety legislation.
Mistake 2: Assuming Cosmetics Are Completely Outside Every GPSR Consideration
The opposite assumption can also be problematic.
Brands should assess whether any relevant safety aspect falls outside the requirements already covered by the applicable specific legislation.
Mistake 3: Using One Compliance Checklist for Every Product
A cosmetic product, consumer accessory and household product may have different legal requirements.
Mistake 4: Focusing Only on Product Launch
Compliance does not end when a product is placed on the market.
Businesses also need appropriate post-market monitoring, documentation and corrective action processes where applicable.
Mistake 5: Treating Online Compliance Separately From Product Compliance
Online listings, product information and marketplace obligations need to align with the underlying regulatory requirements for the product.
How GCRS Can Help
For brands operating across the EU, understanding which regulatory framework applies to each product is an important part of market access planning.
GCRS provides compliance services designed to help brands manage product safety, regulatory documentation, market access and ongoing compliance requirements.
For cosmetic products, GCRS can support areas including:
- Cosmetic regulatory assessment
- EU Responsible Person support
- Product registration
- Safety documentation
- Product Information Files
- Labelling and artwork review
- Claims review
- Testing coordination
- Regulatory monitoring
- Post-market compliance
For products subject to GPSR, GCRS can also support areas such as product safety assessment, technical documentation, traceability, economic operator requirements and post-market obligations.
This allows brands to approach EU compliance based on the actual regulatory requirements of their product portfolio rather than applying a one-size-fits-all checklist.
GCRS responsible person services can also support brands that need an EU regulatory partner for applicable cosmetic products.
A Practical Checklist for Cosmetic Brands
Before launching or reviewing an existing cosmetic product in the EU, ask:
- Is the product correctly classified as a cosmetic?
- Does Regulation (EC) No 1223/2009 apply?
- Has the required cosmetic safety assessment been completed?
- Is the Product Information File complete?
- Is there an appropriate EU Responsible Person?
- Has the product been notified through CPNP?
- Are ingredients compliant with applicable restrictions?
- Is the label compliant?
- Are claims appropriately substantiated?
- Is there a process for managing serious undesirable effects?
- Does the product contain components that may require assessment under another regulatory framework?
- If GPSR is being considered, which specific safety aspects are actually within its scope?
- Are online product listings consistent with the applicable requirements?
- Are post-market monitoring and corrective action processes established?
Conclusion
So, does GPSR apply to cosmetics?
The answer is not simply “yes” or “no.”
Cosmetic products in the EU are primarily governed by the dedicated Cosmetics Regulation, Regulation (EC) No 1223/2009. The GPSR is a general product safety framework and is designed to work alongside specific EU legislation rather than replace it.
Where specific legislation already regulates the safety of a product, GPSR applies only to aspects or risks that are not covered by those specific requirements.
For cosmetic brands, the practical priority is therefore to understand the regulatory classification of each product, identify the legislation that applies and establish which obligations need to be fulfilled at each stage of the product lifecycle.
For businesses selling cosmetics alongside other consumer products, this becomes even more important. A clear regulatory mapping process can help prevent duplicated work while reducing the risk of missing an applicable requirement.
Not sure whether GPSR applies to your product portfolio?
GCRS can help you assess your products, identify the applicable EU regulatory requirements and build a practical compliance pathway for market access.
Speak to our regulatory experts today to review your EU product compliance requirements.
Frequently Asked Questions
- Does GPSR apply to cosmetics in the EU?
Cosmetics are primarily regulated under Regulation (EC) No 1223/2009. Under Article 2 of the GPSR, where specific EU legislation covers the safety requirements for a product, GPSR applies only to aspects or risks that are not covered by that specific legislation.
- Is the EU Cosmetics Regulation different from GPSR?
Yes. The Cosmetics Regulation is a sector-specific framework specifically designed for cosmetic products. GPSR provides a general consumer product safety framework for products and safety aspects not covered by more specific EU legislation.
- Do cosmetic brands need a GPSR technical file?
Not automatically. Brands should first establish which legislation applies to the product and which safety requirements are covered. Cosmetic products have specific documentation requirements under the Cosmetics Regulation, including the Product Information File and Cosmetic Product Safety Report.
- What should a brand do if it sells cosmetics and other consumer products?
The brand should assess each product individually, identify the applicable legislation, assign the relevant economic operator responsibilities and maintain the documentation required for each product category. A product-specific regulatory matrix can help manage different requirements efficiently.
ABOUT THE REVIEWER – DEEPA SINHA
Deepa Sinha Co-founder and CTO at GCRS Group, supporting cosmetic and personal care brands with global regulatory compliance, Responsible Person services, claims review, testing coordination, and international market entry strategy across the UK, EU, USA, UAE, India, and wider global markets.
She works alongside the wider GCRS regulatory team to help brands navigate evolving cosmetic regulations and launch products compliantly across multiple regions.
