How to Sell Cosmetics on Amazon EU: The Complete Compliance Checklist

If you want to sell cosmetics on Amazon EU, you need to meet specific regulatory requirements before your first listing goes live. Amazon's EU marketplaces — Amazon.de, Amazon.fr, Amazon.it, Amazon.es, Amazon.nl, Amazon.pl, Amazon.se, and Amazon.be — collectively represent one of the largest opportunities for cosmetics sellers outside of the United States. But listing cosmetics on any EU Amazon marketplace comes with regulatory requirements that are fundamentally different from selling in the UK or US.

EU Cosmetics Regulation 1223/2009 governs every cosmetic product placed on the EU market, and Amazon enforces these requirements through its own compliance checks. Sellers who do not meet the requirements face listing suppression, inventory holds, and in serious cases, account-level restrictions.

This guide covers every compliance requirement for selling cosmetics on Amazon EU, in the order you need to address them.

Requirement 1: EU Responsible Person

Every cosmetic product sold in the EU must have a designated EU Responsible Person — a legal entity or individual established within the EU who takes responsibility for the product's compliance. This is mandated by Article 4 of Regulation 1223/2009.

If you are based in the UK, the US, or anywhere outside the EU, you cannot act as your own EU Responsible Person. You must appoint one. The EU Responsible Person's name and address must appear on the product packaging, on the CPNP notification, and they must hold the Product Information File at their EU address, available for inspection by competent authorities.

Amazon will ask for your EU Responsible Person details during the listing process for cosmetics. If you cannot provide them, the listing will not proceed. Eldris provides EU Responsible Person appointment through responsible.eldris.ai, with certificates issued in under one hour.

Requirement 2: Cosmetic Product Safety Report (CPSR)

Before any cosmetic product can be placed on the EU market, it must have a completed CPSR — a formal safety assessment conducted by a qualified safety assessor. The CPSR evaluates the toxicological profile of every ingredient, assesses the product's safety in normal and reasonably foreseeable use, and delivers a professional conclusion on whether the product is safe for human health.

Amazon does not typically ask to see the CPSR directly during the listing process. However, the CPSR is a legal prerequisite for the CPNP notification (which Amazon does check), and it must exist within the PIF held by your EU Responsible Person. If a competent authority inspects your EU Responsible Person's records and the CPSR is missing, you are in breach of the regulation — regardless of whether Amazon flagged it.

The CPSR must be produced by a person holding formal qualifications in pharmacy, toxicology, medicine, or an equivalent discipline. It is not a document you can produce yourself. See the CPSR pricing guide for current UK market rates.

Requirement 3: Product Information File (PIF)

The Product Information File is a comprehensive documentation package that must be maintained for every cosmetic product on the EU market. It must be kept at the address of your EU Responsible Person and made available to competent authorities upon request.

The PIF must contain the CPSR, a product description including the product's name and the Responsible Person's details, a description of the manufacturing method, a statement of compliance with Good Manufacturing Practice (ISO 22716), evidence supporting any claims made about the product, data on animal testing, and any existing data on undesirable effects.

Like the CPSR, Amazon does not directly request the PIF during listing. But it is a legal requirement that underpins everything else, and its absence exposes you to regulatory action.

Requirement 4: CPNP Notification

This is where Amazon's compliance checks intersect directly with the regulation. CPNP notification is the electronic submission of product information to the EU Cosmetic Products Notification Portal before the product is placed on the market.

Upon successful notification, the CPNP issues a reference number. Amazon requires this reference number when you list cosmetic products on EU marketplaces. It serves as verifiable proof that the product has been properly notified to EU authorities.

The CPNP reference number is one of the most common compliance gaps for Amazon sellers. Forum discussions and seller communities are full of posts about listings being suspended because the seller either did not have a CPNP reference number or provided an incorrect one. If you search "CPNP reference number Amazon" you will find Reddit threads and seller forums discussing this exact issue — and notably, very few actual service providers offering to solve it.

You cannot obtain a CPNP reference number without first having your CPSR completed and your EU Responsible Person appointed. This is the compliance chain: CPSR feeds into PIF, PIF is held by the EU Responsible Person, and the CPNP notification references all of them.

Requirement 5: EU-Compliant Labelling

EU cosmetics labelling requirements under Article 19 of the regulation are specific and non-negotiable. Your product packaging must display the name and address of the EU Responsible Person, the country of origin (if outside the EU), the nominal content by weight or volume, the date of minimum durability or the period after opening (PAO) symbol, any particular precautions for use, the batch number, the product function (unless obvious from its presentation), and the full list of ingredients in INCI format.

The ingredient list must use the International Nomenclature of Cosmetic Ingredients (INCI) naming system and must be preceded by the word "Ingredients." Allergens listed in Annex III of the regulation must be identified individually at the end of the ingredient list when present above specified concentration thresholds — 0.001% in leave-on products and 0.01% in rinse-off products.

Amazon's product image requirements mean that your labelling will be visible in listing photographs. Non-compliant labels — missing EU Responsible Person details, absent INCI list, no PAO symbol — can trigger compliance reviews and removal.

For detailed guidance on what must appear on your packaging, see the EU cosmetics labelling requirements guide.

Requirement 6: Good Manufacturing Practice (GMP)

EU Cosmetics Regulation requires that cosmetic products are manufactured in accordance with Good Manufacturing Practice as defined by ISO 22716. You must be able to demonstrate GMP compliance — either through an ISO 22716 certificate from your manufacturer or through a signed GMP statement confirming that manufacturing processes meet the standard.

This document is part of the PIF and is reviewed during the CPSR process. If your manufacturer cannot provide GMP evidence, this is a compliance gap that needs resolving before you can proceed with the rest of the documentation chain.

What Happens When Amazon Flags You

Amazon's compliance enforcement for cosmetics on EU marketplaces takes several forms. Listing suppression is the most common — your product disappears from search results and the product page shows as unavailable. You will typically receive a notification in Seller Central asking you to provide compliance documentation, which may include your CPNP reference number, EU Responsible Person details, Safety Data Sheets, or test certificates.

In more serious cases, Amazon may place an inventory hold on FBA stock, preventing you from creating removal orders until the compliance issue is resolved. Account-level restrictions can follow if multiple products are flagged or if you fail to respond to compliance requests within the timeframe given.

The resolution process involves providing the requested documentation through Seller Central's compliance portal. Having all your documentation already in place — CPSR, PIF, CPNP reference number, EU Responsible Person certificate — means you can respond immediately rather than scrambling to arrange compliance from scratch while your listings are down and your inventory is frozen.

The Compliance Checklist

Here is the complete sequence for getting a cosmetic product compliant for Amazon EU sale.

Step 1: Gather your product documentation — full formula with percentages, Safety Data Sheets for every ingredient, Certificates of Analysis, stability test data, challenge test data (for water-based products), IFRA certificate (for fragranced products), GMP certificate or statement, and product photographs and label artwork.

Step 2: Appoint an EU Responsible Person established within the EU. This can be done through responsible.eldris.ai.

Step 3: Have your CPSR produced by a qualified safety assessor.

Step 4: Compile the Product Information File containing the CPSR and all supporting documentation.

Step 5: Submit the CPNP notification and obtain your reference number.

Step 6: Ensure your product labelling meets all EU requirements including EU Responsible Person details, INCI ingredient list, and durability marking.

Step 7: Create your Amazon EU listing with the CPNP reference number and EU Responsible Person details.

Eldris Cosmetics handles steps 2 through 6 as a done-for-you service. You provide the raw documentation from step 1, and Eldris delivers everything you need to complete step 7. View pricing and get started.