Selling cosmetics online in the EU changed on 13 December 2024, when the General Product Safety Regulation (EU) 2023/988 became applicable. The part that affects beauty brands most is not a safety requirement at all. It is Article 19, which sets out the information that must appear in the online offer itself, before the consumer buys.
Marketplaces have been enforcing it aggressively, because they carry their own obligations under the same regulation. Listings get suspended for missing manufacturer details or missing warnings, and the seller usually finds out through a delisting notice rather than through an authority. This guide sets out what a compliant cosmetic listing contains, how the GPSR interacts with cosmetic law, and what else changed for online sellers.
Key takeaways
- The GPSR has applied since 13 December 2024 and covers aspects of consumer product safety not addressed by sector specific legislation.
- Article 19 requires the online offer to show manufacturer details, the details of the responsible economic operator in the EU, product identification and warnings, before purchase.
- There must be an economic operator established in the EU responsible for the product, which for cosmetics is normally satisfied by the Responsible Person.
- Warnings and safety information must be given in a language easily understood by consumers in the market you are selling to.
- Accidents caused by a product must be notified through the Safety Business Gateway, and recalls must follow the prescribed notice format and remedies.
- Marketplaces are enforcing this directly, so a listing can be removed without any regulator becoming involved.
- The cosmetic obligations under Regulation (EC) 1223/2009 continue unchanged, and the two sets of rules run in parallel.
How the GPSR fits alongside cosmetic law
The GPSR is a safety net. Where sector specific EU legislation covers an aspect of product safety, that legislation applies, and the GPSR fills the gaps. Cosmetics have detailed sectoral rules on safety assessment, notification, labelling and market surveillance, so those are unaffected.
What the Cosmetic Regulation does not address is the modern retail environment: what a distance selling listing must show, how accidents are reported, how a recall is communicated and what remedies a consumer is entitled to. That is where the GPSR bites, and it is why the practical impact for cosmetic brands has been felt on product pages rather than in laboratories.
The safety documentation itself does not change. You still need a safety assessment, a product information file and a CPNP notification exactly as before. If you are unsure about that baseline, our guide to whether you need a CPSR to sell online covers it.
What a compliant listing shows
Article 19 sets a short list, and the wording matters: the information must be clear and visible in the offer itself, not buried in a linked document or supplied after purchase.
| Element | What it means in practice |
|---|---|
| Manufacturer identity | Name, registered trade name or trade mark, plus postal and electronic address |
| EU responsible operator | Where the manufacturer is outside the EU, the name, address and email of the economic operator established in the Union |
| Product identification | Product type, batch or serial identifier, and a picture of the product |
| Warnings and safety information | The warnings that appear on the pack, in a language easily understood by consumers in that market |
For a cosmetic sold by an EU brand, the manufacturer details and the responsible operator details are usually the same entity. For an imported product, the two are different, and both have to appear. This is the single most common reason a cosmetic listing gets suspended: the brand shows its own name and a website contact form, with no address and no EU operator details.
Warnings, in practice
Copy the warnings from the pack. If your label says to avoid contact with the eyes, to keep out of reach of children, or carries the annex mandated wording for a restricted ingredient, that text belongs in the listing. Where you sell into several markets, it belongs in each market’s language, which is the same obligation the pack already carries and is covered in our note on country specific labelling obligations.
It is also good practice to publish the full ingredient list online. It is not something the GPSR asks for, but consumers with allergies expect it, several national authorities take the view that mandatory label information should be available before purchase, and it prevents a category of return and complaint.
Marketplace compliance systems are automated and blunt. A listing missing a postal address will often be suspended without a human reading it, and reinstatement takes days. Fixing your listing template once, across the whole catalogue, is far less painful than handling suspensions product by product during a peak trading period.
Accidents, recalls and the Safety Gate
Two obligations catch brands unprepared because they are not part of the launch checklist.
Accident notification
Where a product you have placed on the market has caused an accident resulting in serious harm, you must notify the competent authorities through the Safety Business Gateway without delay. This is separate from the serious undesirable effects reporting that already exists under Article 23 of the Cosmetic Regulation, and the two can both apply to the same event.
Recall communication
The GPSR prescribes how a recall notice must be written and what it must contain, and it entitles consumers to a remedy: repair, replacement or refund, with at least two options offered. It also requires you to contact affected consumers directly where you have their details, which for a direct to consumer brand means using your order database rather than posting a notice on a website.
Our article on what happens if you sell non-compliant cosmetics covers the enforcement side, and the GPSR adds a defined procedure to it.
Technical documentation and traceability
The GPSR expects an internal risk analysis and technical documentation kept for ten years, proportionate to the product. For a cosmetic, most of that content already exists in the product information file, so the sensible approach is to map rather than duplicate: point to the safety assessment, the formula, the manufacturing information and the label, and add whatever is genuinely missing, such as your risk analysis for packaging and foreseeable misuse.
Traceability is the other half. You need to identify the economic operators who supplied you and to whom you supplied, which for online sellers means keeping distributor records rather than relying on order emails. Our guide to GPSR technical documentation sets out the file structure.
A listing template that works
The fastest fix is to build one block and apply it across every product page:
- Manufacturer name, postal address and email.
- EU responsible operator name, address and email, where the manufacturer is outside the EU.
- Product identification, including the variant, size and batch information where the platform supports it, with a clear product image.
- Warnings reproduced from the pack, in the language of the market.
- Full ingredient list and period after opening, as good practice.
- Contact route for safety queries that a consumer can actually use.
If you sell through marketplaces as well as your own store, apply the same block everywhere. Platforms differ in which fields they expose, so check that your data actually renders on the public page rather than sitting in a back office field. Our note on selling cosmetics on Amazon in the EU covers the documentation side of marketplace selling.
Bringing it all together
The GPSR did not make cosmetics harder to sell, it made the shop window part of the regulated product. The safety file, the notification and the label obligations are unchanged. What is new is that the listing itself must carry identity, identification and warning information, that accidents have a defined reporting route, and that recalls have a defined format with consumer remedies attached.
Treat it as a template problem, not a product problem. Build one compliant information block, apply it across the catalogue, keep your technical documentation mapped to the product information file you already have, and make sure someone in the business knows how the Safety Business Gateway works before you need it.
Lexora prepares GPSR technical documentation for cosmetic ranges and reviews listings and packs against both frameworks. Start with GPSR technical documentation guidance, add a cosmetic label review, or take the whole route to market with the full compliance pack.
Frequently asked questions
Does the GPSR apply to cosmetics?
Yes, for aspects not covered by the Cosmetic Regulation. Safety assessment, notification and labelling continue to be governed by Regulation (EC) 1223/2009, while the GPSR adds obligations on online offers, accident notification, recall procedures and consumer remedies.
What must appear on an online cosmetic listing?
The manufacturer’s name, postal address and electronic address, the details of the responsible economic operator established in the EU where the manufacturer is outside it, product identification including a picture, and the warnings and safety information in a language easily understood by consumers in that market.
Is my Responsible Person the same as the GPSR economic operator?
In most cases the entity that acts as Responsible Person under the Cosmetic Regulation also satisfies the requirement for an economic operator established in the Union. Confirm the arrangement in your contract, since the tasks under each regime are defined separately and the contact details you publish must be accurate for both.
Why did my marketplace listing get suspended?
Usually because a required Article 19 field is missing, most often a postal address or the EU operator details. Marketplaces have their own obligations under the GPSR and enforce automatically, so listings are suspended before any authority is involved. Fixing the listing template across the catalogue prevents repeats.
Do I need separate technical documentation for the GPSR?
You need documentation including a risk analysis, kept for ten years, but most of the content already exists in your cosmetic product information file. Map to what you have and add the genuinely missing pieces, rather than building a parallel file that will drift out of date.
What do I do if a customer is injured by my product?
Where the accident caused serious harm, notify the competent authorities through the Safety Business Gateway without delay. Consider separately whether the event is a serious undesirable effect requiring notification under Article 23 of the Cosmetic Regulation, since both obligations can apply to the same incident.
