In our last post we covered CPNP notification and why it’s mandatory before any cosmetic product reaches the EU market. We mentioned, almost in passing, that CPNP notification depends on something called a CPSR. That deserves its own explanation, because it’s arguably the more important document of the two — CPNP is the notification, but the CPSR is the actual proof that your product is safe to sell.

A lot of brands hear “safety report” and assume it’s a formality — something a lab signs off on and files away. It isn’t. A proper CPSR is a detailed, legally required assessment that has to hold up under scrutiny if a regulator, a retailer, or a consumer ever asks questions about your product. Here’s what’s actually in it.

What CPSR Stands For, and Where It Comes From

CPSR stands for Cosmetic Product Safety Report. Like CPNP, it’s a requirement under EU Regulation (EC) No 1223/2009 — specifically Annex I, which lays out exactly what the report has to contain. Every cosmetic product sold in the EU needs one, and it has to exist before the product is notified through CPNP, not after.

The report is split into two parts: Part A covers the cosmetic product safety information itself — the raw data. Part B is the safety assessment — a qualified assessor’s professional conclusion, based on that data, that the product is safe for its intended use.

What’s Actually Inside Part A

Part A is where the detail lives. It includes:

• The full quantitative and qualitative formula, ingredient by ingredient
• The physical, chemical, and microbiological characteristics of the product
• Impurities, trace substances, and packaging material information, since packaging can interact with a formula over time
• The exposure conditions — how much product is used, how often, and how it’s applied (a rinse-off shampoo and a leave-on serum are assessed very differently)
• Toxicological profiles for each ingredient, including data on things like skin sensitisation, irritation, and any CMR (carcinogenic, mutagenic, reprotoxic) classifications
• Undesirable effects and serious undesirable effects reported for the product or similar formulations

This is also where nanomaterials get flagged separately if they’re present, since those carry additional regulatory scrutiny.

What’s Actually Inside Part B

Part B is the assessor’s conclusion — but it’s not a rubber stamp. A qualified safety assessor (someone with a specific academic background recognised under the regulation, typically in pharmacy, toxicology, medicine, or a related field) has to review everything in Part A and reach a reasoned judgment on whether the product is safe under normal and reasonably foreseeable use.

This section also documents:

• The assessor’s reasoning, not just their conclusion
• Warnings and instructions for use that need to appear on the label as a result of the assessment
• The assessor’s qualifications, since this isn’t something just anyone can sign off on

If a regulator ever challenges a product’s safety, this is the section that gets examined first. A vague or copy-pasted Part B is one of the fastest ways a brand ends up in a drawn-out compliance dispute.

Why Brands Underestimate This Document

The reason CPSR trips brands up more than CPNP itself is that it requires real technical and toxicological expertise, not just administrative filing. You can’t write an adequate Part B without genuinely understanding the formula’s ingredients, their known hazard profiles, and how they behave in combination.

We regularly see two versions of this mistake:

The first is brands who treat the CPSR as boilerplate — reusing a template from a similar product without adjusting it for their specific formula, concentration levels, or claims. This tends to surface during a market surveillance check, which is the worst possible time to discover a gap.

The second is brands who assume their manufacturer or contract filler has already handled it. Sometimes they have. 

How CPSR Connects to CPNP, PIF, and Your Label

The CPSR doesn’t exist in isolation.

The CPSR is one of the core documents in your Product Information File (PIF), and you must keep it available for inspection by the authorities at all times—not just file it once and forget about it. It also plays a direct role in shaping your product label. As we covered in our last post, your CPNP notification also depends on a valid CPSR. Skip or rush the CPSR, and every document downstream of it inherits the same weakness.

Getting a CPSR Done Properly

A CPSR isn’t something to piece together after the fact or delegate to whoever happens to have a chemistry background. A Cosmetic Product Safety Report (CPSR) isn’t just a document to tick a compliance box.

A qualified safety assessor who understands both the regulation and your specific formula should prepare your CPSR. They should also base it on the product exactly as you will manufacture, package, and sell it.
Need a CPSR prepared or reviewed?