Note: This article provides a general overview for educational purposes. It is not legal advice. Always consult a qualified regulatory consultant or legal professional before placing your product on the EU market.
The regulatory framework: EU Cosmetics Regulation 1223/2009
All cosmetic products sold in the EU — including fragrances — are governed by Regulation (EC) No 1223/2009. This regulation covers everything from ingredient safety and labelling requirements to the role of the Responsible Person (RP) and the requirement for a Cosmetic Product Safety Report (CPSR).
If you are an independent brand placing a fragrance on the EU market for the first time, understanding this framework is non-negotiable. The consequences of non-compliance include product withdrawal, fines, and reputational damage.
The Responsible Person
Every cosmetic product sold in the EU must have a designated Responsible Person — a legal entity established within the EU that takes regulatory responsibility for the product. If your company is based in Turkey, the US, or the UK post-Brexit, you cannot be your own RP. You will need to appoint an EU-based RP, which is typically a specialist regulatory services firm.
RP services typically cost between €200–800 per product per year, depending on complexity and the service provider.
Cosmetic Product Safety Report (CPSR)
Before a fragrance can be placed on the EU market, it requires a CPSR — a document prepared by a qualified safety assessor that evaluates the safety of all ingredients and the finished formula. This assessment references the IFRA (International Fragrance Association) standards and EU restricted substance lists.
A CPSR for a standard fragrance formulation typically costs €300–600 and takes 2–6 weeks to prepare. You will need your complete formula (all ingredients with CAS numbers and percentages) to commission one.
CPNP notification
Before your product goes on sale in the EU, it must be notified on the Cosmetic Products Notification Portal (CPNP). This is done by your RP and requires the product name, category, formula (at ingredient level), and safety report reference. CPNP notification is free and takes a few hours once all documentation is ready.
Packaging labelling requirements
EU Cosmetics Regulation specifies what must appear on your packaging. For a perfume bottle, the mandatory label elements are:
- The name and address of the Responsible Person (within the EU)
- Country of origin (if manufactured outside the EU)
- Nominal content (weight or volume)
- Date of minimum durability (PAO symbol — the open jar icon — for products stable beyond 30 months, or a specific "best before" date for shorter-lived products)
- Precautions for use (particularly relevant for high-allergen fragrances)
- Batch number (for traceability)
- Function of the product (e.g. "Eau de Parfum")
- List of ingredients in INCI nomenclature (can be on an enclosed leaflet if the packaging is too small)
Additionally, from March 2025, allergen disclosure requirements were updated to require individual labelling of 56 fragrance allergens above specific concentration thresholds. Ensure your safety assessor and label designer are working to the current list.
What this means for your packaging choice
All of the above has a practical implication for how you order your bottles: do not commit to printed glass (screen print, hot stamp, or embossed) before your label content is finalised. Regulatory changes, formula updates, or address changes for your RP can require label revisions — and if your label is in the glass itself, that becomes expensive.
The industry standard approach for emerging brands is: order blank glass, apply a high-quality printed label. Only move to glass-integrated branding (embossing, silk print) once the product and all regulatory details are stable.
Where to get help
Several firms specialise in EU cosmetic regulatory compliance for small brands, including Cosmetic Valley regulatory services, QualityAssurance.eu, and many national cosmetic trade associations. For the UK market (post-Brexit), the CTPA (Cosmetic, Toiletry and Perfumery Association) provides guidance. Budget for regulatory compliance from the start — it is a cost of doing business in the EU, not an optional extra.
Questions about your specific situation?
We can't provide regulatory advice, but we can connect you with specialists we work with. Write to us and we'll point you in the right direction.
