Compliance, CPSR, Perfume Making

Understanding Cosmetic Product Safety Reports (CPSR)

Posted on by Perfume Extract
CPSR
23
May

Understanding Cosmetic Product Safety Reports (CPSR): Requirements, Responsibilities, and Assessors

Bringing a cosmetic product to market in the UK or EU requires compliance with strict safety and regulatory standards. One of the most important documents in this process is the Cosmetic Product Safety Report (CPSR). This article explains what a CPSR is, who is responsible for its creation, and how Safety Data Sheets (SDS), qualified assessors, and supplier limitations fit into the process.

 

What is a CPSR?

A Cosmetic Product Safety Report (CPSR) is a mandatory assessment for any cosmetic product sold within the UK or EU. It evaluates the safety of the finished product for its intended use and ensures compliance with:

  • EU Cosmetic Regulation (EC) No 1223/2009, particularly Annex I & III

  • UK Cosmetics Regulation 2019, Schedule 34

The CPSR is a critical document for demonstrating that your cosmetic product meets legal obligations, covering ingredients, concentrations, exposure, toxicological data, and potential allergens.

 

Who is responsible for a CPSR?

Legally, the responsible person—typically the manufacturer, importer, or distributor placing the product on the market—is accountable for CPSR compliance. Suppliers like Perfume Extract and other similar manufacturers are not responsible for CPSR compliance.

Key points:

  • Suppliers provide SDS for raw materials but do not guarantee additional documentation such as IFRA certificates, Certificates of Analysis (CoA), allergen declarations, or Annex VIII / PCN composition data unless explicitly stated on the product page.

  • Any CPSR assessor must be fully qualified to interpret ingredient data, SDS, toxicology reports, and EU/UK regulatory frameworks.

  • Brand owners and responsible persons are solely responsible for ensuring regulatory compliance and product safety.

 

What information is needed for a CPSR?

A qualified CPSR assessor generally requires:

  1. Full product formula, including ingredient percentages.

  2. Safety Data Sheets (SDS) for each ingredient.

  3. Publicly available toxicological data for additional safety context.

  4. Any legally required documentation for allergens or restricted substances (where applicable).

Important: Suppliers like Perfume Extract provide SDS only. Additional documentation may only be supplied if explicitly listed in the Datasheets tab of the product page. SDS alone form the legal and practical basis for CPSR assessment.

 

Using SDS for CPSR Assessment

SDS are primarily designed for CLP classification (hazard identification, safe handling, and storage). However, a fully qualified CPSR assessor can use SDS, along with your product formula and publicly available toxicological information, to complete a CPSR.

This approach is consistent with UK and EU law:

  • EU Cosmetic Regulation (EC) No 1223/2009, Annex I & III – specifies the data and toxicological evaluation required.

  • UK Cosmetics Regulation 2019 – aligns with EU provisions post-Brexit.

An SDS is only mandatory under REACH where a substance or mixture meets hazard classification criteria or where specific regulatory conditions apply, including where hazardous ingredients are present above defined concentration thresholds.

Relevant legislation:

Under REACH Article 31, providing a compliant Safety Data Sheet constitutes the supplier’s legal obligation to communicate hazard and safety information for substances and mixtures within the supply chain. SDS therefore represent the legally recognised regulatory documentation for chemical raw materials supplied to professional users.

If placing finished products on the market requires a CPSR, it is your responsibility to engage a fully qualified assessor, such as a member of the Royal Society of Chemistry (RSC) or the British Toxicology Society (BTS). Failure to appoint a qualified assessor, or to ensure regulatory compliance, does not create any liability for the products or the legally supplied documentation. Use of off-the-shelf or resold CPSRs, or advice obtained outside engagement with a competent assessor, cannot override legal compliance or the safety of raw materials supplied under applicable UK and EU chemical legislation.

 

IFRA Certificates

IFRA Standards are voluntary industry guidelines, not mandatory under UK or EU law, and are issued only for finished fragrance compounds, not single aroma chemicals.

A qualified Cosmetic Product Safety (CPS) assessor will normally calculate IFRA compliance and allergens for a finished formulation using:

IFRA’s guidance confirms that certificates are issued by manufacturers of finished fragrance mixtures only: https://ifrafragrance.org/standards/ifra-certification

 

Certificates of Analysis (CoA) and Allergen Statements

CoAs are quality verification documents issued by manufacturers but are not legally required for individual raw materials under UK/EU law.

Supplier-provided allergen declarations for raw materials are voluntary, and obligations for allergens only apply at the finished cosmetic product level (EU Cosmetic Regulation (EC) No 1223/2009, Annex III).

Reference:

Qualified assessors rely primarily on SDS, formula, and public toxicological information. Requests for CoA, allergen statements, or IFRA certificates from suppliers for raw materials are red flags indicating the assessor may be inexperienced, unqualified, or using an off-the-shelf CPSR approach.

 

Natural Materials and UVCB Substances

Some natural ingredients, like Benzoin resin, are supplied as tinctures and fall under the UVCB classification (Unknown or Variable composition, Complex reaction products, or Biological materials).

  • This classification is standard under chemical regulations and does not alter CPSR requirements.

  • Supplier-issued allergen certificates are typically not provided and are not mandated under EU cosmetic legislation.

  • SDS remain the primary documentation for CPSR assessment.

 

 

Selecting a CPSR Assessor

Not all cosmetic consultants or off-the-shelf CPSR services are qualified. When selecting an assessor, ensure they:

Do:

  • Have formal training in cosmetic toxicology or regulatory compliance.

  • Are members of the Royal Society of Chemistry (RSC) and British Toxicology Society (BTS).

  • Are familiar with EU/UK Cosmetic Regulations, including EC 1223/2009 (Annex I & III) and UK Cosmetics Regulation 2019 (Schedule 34).

  • Have the ability to interpret SDS, assess ingredient safety, allergen content, and potential restricted substances.

  • Have experience with raw fragrance materials, including natural extracts and UVCB substances, not just finished fragrance oils.

  • Can provide a formal CPSR report with signature or professional validation.

  • Are aware of SCCS guidance notes and can apply them appropriately as guidance, not legal mandate.

  • Follow a documented, transparent methodology, showing how they use SDS, your formula, and publicly available toxicological information.

  • Can provide references or examples of similar CPSRs they have successfully completed.

Do not engage an assessor who:

  • Insists that the responsible person (brand owner) or supplier must provide IFRA, CoA, or Annex VIII data for raw materials; such requests often come from organisations offering cheap or off-the-shelf CPSRs.

  • Is unfamiliar with raw fragrance materials and only understands finished fragrance oils, leading to unnecessary document requests.

  • Is unverified, freelance, or lacks formal qualifications in cosmetic toxicology.

  • Claims additional documentation is legally required without being able to justify it under relevant legislation.

  • Promises CPSR completion without reviewing your formula or SDS in detail, indicating a template or shortcut approach.

  • Quotes a fixed, low fee without clarifying the scope of assessment, ignoring the technical work required.

  • Creates conflict by insisting on unnecessary supplier engagement for documents not required by law.

  • Cannot explain how their methodology ensures compliance with EC 1223/2009 Annex I & III or Schedule 34 of the UK Cosmetics Regulation 2019.

Practical tip:

Do not commit to a CPSR service without asking:

“Can the CPSR be completed using only the legally required SDS, my formula, and publicly available toxicological information?”

This ensures that your assessor is competent, legally aware, and able to properly assess raw fragrance materials, reducing the risk of delays, unnecessary document requests, and conflict with suppliers.

 

Red Flags, Low-Cost Assessors, and Practical Guidance

Red flags for unqualified or low-quality CPSR assessors:

  • Assessors insisting that suppliers must provide IFRA certificates, Certificates of Analysis (CoA), allergen declarations, or Annex VIII / PCN composition data for raw fragrance materials.

  • Off-the-shelf or generic CPSR services that claim they can prepare a CPSR for all ingredients without reviewing SDS or understanding the raw materials.

  • Assessors unfamiliar with UVCB substances or naturally derived ingredients, who treat all raw materials as if they were finished fragrances.

  • Requests for unnecessary documentation or additional supplier engagement beyond legally required SDS.

  • Lack of formal qualifications in cosmetic toxicology or regulatory compliance.

  • Unverified credentials, freelance profiles without references, or mass-market assessment packages/subscriptions.

  • Assessors who cannot justify in law the legislative basis for claiming additional documentation beyond SDS is required.

  • Assessors who fail to explain how they will complete the CPSR using SDS, your formula, and publicly available toxicological data.

 

 

Price Guidance & Low-Cost CPSR Pitfalls

Be cautious with low-cost CPSR services or off-the-shelf assessments. Price alone is not an indicator of competence. Some inexpensive providers may only be familiar with finished fragrance oils rather than raw fragrance materials and may insist on unnecessary documentation such as IFRA certificates, CoA, or allergen statements. This is often because the service does not support the additional work required to complete a legally compliant CPSR for raw ingredients.

Ask explicitly:

“Can the CPSR be completed using only the legally required SDS, my formula, and publicly available toxicological information?”

Only engage assessors who can confidently answer yes and demonstrate relevant qualifications (e.g., RSC or BTS membership) for raw fragrance materials.

Illustrative real-world scenarios:

  1. Scenario 1: A small brand purchased an off-the-shelf CPSR package for £150. The assessor insisted that all raw aroma chemicals required IFRA certificates and CoA for each ingredient. In reality, these documents were not legally required for raw fragrance materials, and the supplier could not provide them. The brand wasted time and risked regulatory confusion due to the assessor’s lack of understanding of raw materials versus finished fragrances.

  2. Scenario 2: Another business engaged a low-cost freelance CPSR assessor who demanded allergen declarations for every essential oil in the formulation. This assessor was only familiar with finished fragrance products. The company initially delayed product launch, assuming additional documentation was required, until they consulted a qualified toxicologist who confirmed SDS were sufficient.

These examples highlight that cheap or generic services can create unnecessary friction between suppliers and customers and often fail to provide legally defensible assessments.

 

 

SCCS Guidance

The Scientific Committee on Consumer Safety (SCCS) publishes guidance notes for cosmetic safety assessments. These notes provide useful best-practice advice, but they do not constitute legal requirements. A competent assessor will be familiar with SCCS guidance and use it appropriately alongside SDS, your formula, and publicly available toxicological data.

 

Key Responsibilities for Brand Owners

As the responsible person for a cosmetic product:

  • Verify ingredient documentation: Ensure SDS are available for all raw materials.

  • Engage a qualified assessor: Only a fully qualified CPSR assessor can legally prepare the report.

  • Document decisions: Retain CPSR assessments, calculations, and communications.

  • Accept supplier limitations: Understand that suppliers may not provide CoA, IFRA, or Annex VIII data unless explicitly stated.

  • Avoid reliance on informal sources: Emails, verbal statements, or off-the-shelf CPSRs cannot replace qualified assessment.

By understanding these responsibilities, you reduce the risk of regulatory non-compliance, product recalls, or legal action.

 

Common Misconceptions

  • “IFRA certificates are available for all raw materials.”

    Not true. IFRA certificates generally apply to finished fragrance mixtures, not raw materials. SDS + qualified assessor is sufficient.

  • “I must have CoA for all raw materials.”

    CoA is voluntary and primarily a batch quality verification tool. Raw materials can be legally supplied without a CoA.

  • “I need allergen statements from suppliers for raw ingredients.”

    Only the finished product requires allergen labeling. SDS provide sufficient information for raw materials in CPSR assessment.

  • “SDS alone are insufficient for a CPSR.”

    Qualified assessors can complete CPSR using SDS, formula, and publicly available toxicology. SDS form the legal and practical basis for ingredient safety evaluation.

  • “Suppliers are responsible for CPSR compliance.”

    Incorrect. Suppliers provide ingredient information but cannot interpret or certify your CPSR.

  • “Cheap CPSRs or off-the-shelf reports are sufficient.”

    Often inadequate for raw fragrance materials, may demand unnecessary documentation, and can create conflict with suppliers. Engage only fully qualified assessors (RSC/BTS members) to avoid regulatory or legal issues.

  • “Assessors can demand IFRA, CoA, or allergen statements for raw materials.”

    Requests for these often indicate an inexperienced or low-cost assessor. Legal CPSR assessment for raw materials relies on SDS, formula, and publicly available toxicological information.

 

CPSR Documentation Cheat Sheet for Fragrance Raw Materials

Documentation

Required?

Notes / References

Safety Data Sheet (SDS)

✅

Legally required, forms CPSR basis. ECHA Guidance

IFRA Certificates

❌

Only for finished fragrance mixtures, voluntary. IFRA Guidance

Certificate of Analysis (CoA)

❌

Optional quality verification

Allergen Statements

❌

Required only for finished products. EC 1223/2009 Annex III

Annex VIII / PCN Data

❌

Only if explicitly provided by supplier

Other Supplier Documents

❌

Optional; assessors rely on SDS, formula, and public toxicology

How to Avoid Delays or Problems

  • Review product pages and Datasheets tabs carefully; only use raw materials with SDS available.

  • Understand supplier policies; additional documentation beyond SDS is not guaranteed.

  • Engage a fully qualified CPSR assessor early in product development.

  • Document all communications; avoid relying on emails, informal messages, or verbal statements.

  • Do not use off-the-shelf CPSRs or unqualified assessors; these may lack professional support and misstate regulatory requirements.

  • Conduct due diligence on your assessor; ensure they are competent for raw fragrance materials, not just finished oils.

 

References & Further Reading

 

Perfume Extract

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