Does GPSR apply to cosmetics sold online in the EU?

Cosmetics occupy a specific position in the GPSR's framework. They are not fully exempt — but they are primarily regulated by a different piece of EU legislation: Regulation (EC) 1223/2009 on cosmetic products. The relationship between the two regulations is governed by Article 2.3 of the GPSR: the GPSR applies to cosmetics only for safety aspects and risks that the Cosmetics Regulation does not address. In practice, this means the Cosmetics Regulation is the primary compliance framework for cosmetic product safety, formulation, labelling, and the Product Information File (PIF) — while the GPSR applies subsidiarily, filling any gaps.

For cosmetics sold online, however, the GPSR's online-specific provisions apply regardless of the cosmetics exemption. Article 19 of the GPSR — which requires online product listings to display manufacturer details, Responsible Person contact information, a product image, and safety information before purchase — is interpreted by the Commission's Guidelines C(2025) 7699 as applying to all products sold online, including those with their own sector-specific regulation. This is confirmed in practice by Amazon, which requests EU Responsible Person and manufacturer information in Seller Central for cosmetics listings in the same way as for any other product category. Sellers of cosmetics on Amazon who have not provided this information will see their listings flagged for compliance action.

For independent or handmade cosmetics sellers — a rapidly growing category particularly in candle-making, soap-making, and skincare — the compliance picture is multi-layered. The primary obligation comes from Regulation (EC) 1223/2009: every cosmetic product sold in the EU must have a safety assessment carried out by a qualified cosmetic safety assessor, a Product Information File (PIF) held by a Responsible Person (defined differently in the Cosmetics Regulation from the GPSR), and notification through the CPNP (Cosmetic Products Notification Portal). These requirements exist independently of the GPSR. The GPSR then adds the online listing information obligations under Article 19 and may require additional documentation for any product-safety aspects the Cosmetics Regulation does not cover — for instance, for a combined product that includes a non-cosmetic component.

What the law says

Consequences of non-compliance