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.

  • 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:

  • Full product formula, including ingredient percentages.

  • Safety Data Sheets (SDS) for each ingredient.

  • Publicly available toxicological data for additional safety context.

  • Any legally required documentation for allergens or restricted substances (where applicable at finished product level).

Important: Perfume Extract provide SDS as required in law. Additional documentation may only be supplied if explicitly listed in the Datasheets tab of the product page. SDS form the legal and practical foundation 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

  • UK Cosmetics Regulation 2019

An SDS is required under REACH where a substance or mixture meets hazard classification criteria or specific regulatory conditions.

Relevant legislation:

  • UK REACH Regulation (retained EU law):

    https://www.legislation.gov.uk/eur/2006/1907/contents

  • REACH Article 31 – Requirements for Safety Data Sheets:

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02006R1907-20220128#art_31

  • Commission Regulation (EU) 2020/878 (SDS format):

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020R0878

  • CLP Regulation:

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008R1272

  • ECHA Guidance on SDS:

    https://echa.europa.eu/guidance-documents/guidance-on-reach

Under REACH Article 31, providing a compliant SDS constitutes the supplier’s legal obligation to communicate hazard and safety information.

If placing finished products on the market requires a CPSR, it is your responsibility to engage a fully qualified assessor (e.g. members of the Royal Society of Chemistry or British Toxicology Society). Failure to do so does not transfer liability to the supplier.

 

Legal Requirements vs Industry Practice (Important Distinction)

It is important to distinguish between legal requirements under UK/EU cosmetic legislation and industry practices or assessor preferences.

Under EU Cosmetic Regulation (EC) No 1223/2009 (Annex I) and the UK Cosmetics Regulation 2019, a CPSR must include a safety assessment based on:

  • Ingredient composition

  • Toxicological profiles

  • Exposure assessment

  • Margin of safety

The legislation does not prescribe specific document formats (such as IFRA certificates, CoA, or supplier allergen declarations) as mandatory inputs.

 

 

Role of Additional Documentation

In practice, some assessors may request:

  • IFRA Certificates

  • Certificates of Analysis (CoA)

  • Allergen Declarations

  • Annex VIII / PCN data

These may be used as supporting tools, but:

  • They are not universally required under law for raw materials

  • Availability depends on the supply chain

  • They do not replace toxicological assessment

 

SCCS Guidance vs Legal Obligation

SCCS provides guidance, not law:

https://health.ec.europa.eu/publications/sccs-notes-guidance_en

  • SCCS = best practice guidance

  • Not legally binding

  • Applied differently by assessors

 

Competency of the Assessor

A competent assessor must:

  • Interpret SDS

  • Source toxicological data

  • Apply scientific judgement

If they cannot complete a CPSR without non-mandatory documents, this reflects methodology limitations, not legal requirements.

 

 

IFRA Certificates

IFRA Standards are voluntary and not legally required under UK/EU law for raw materials.

  • IFRA Standards: https://ifrafragrance.org/safe-use/standards

  • IFRA Certification: https://ifrafragrance.org/standards/ifra-certification

IFRA certificates apply to finished fragrance compounds, not individual raw materials.

Assessors typically calculate compliance using:

  • SDS

  • formulation percentages

  • IFRA standards

 

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.

  • CoAs are not a legal requirement for raw materials

  • Allergen obligations apply to the finished product only

References:

  • EU Regulation Annex III:

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R1223

  • UK Cosmetics Regulation Schedule 34:

    https://www.legislation.gov.uk/uksi/2019/696/schedule/34/made

Requests for these documents for raw materials may indicate a standardised or template-based assessment 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 is normal under chemical regulation

  • Does not change CPSR requirements

  • SDS remains the primary documentation

Supplier allergen certificates are not mandated.

 

 

Selecting a CPSR Assessor

Not all cosmetic consultants or off-the-shelf CPSR services are qualified.

When selecting an assessor, ensure they:

  • Have formal training in cosmetic toxicology or regulatory compliance.

  • Are members of recognised professional bodies such as the Royal Society of Chemistry (RSC) or the British Toxicology Society (BTS).

  • Have a clear understanding of EU and UK cosmetic regulations, including Regulation (EC) No 1223/2009 and the UK Cosmetics Regulation 2019.

  • Are able to interpret Safety Data Sheets (SDS) correctly and assess ingredient safety, allergen content, and potential restricted substances.

  • Have experience working with raw fragrance materials, including natural ingredients and UVCB substances.

  • Provide a formal CPSR report with appropriate signature or professional validation.

  • Apply SCCS guidance appropriately as guidance rather than as a legal requirement.

  • Use a transparent and explainable methodology when preparing CPSRs.

Consider carefully before engaging an assessor who:

  • Insists that suppliers must provide IFRA certificates, Certificates of Analysis (CoA), or Annex VIII / PCN data for raw materials.

  • Has experience primarily with finished fragrance oils rather than raw fragrance materials.

  • Does not clearly demonstrate relevant qualifications or verifiable experience.

  • States that additional documentation is required without being able to reference the relevant legal basis.

  • Relies on highly standardised or template-based CPSR approaches without considering the specific formulation.

  • Does not review SDS or formulation details in sufficient depth.

  • Is unable to explain how their assessment meets the requirements of Annex I of Regulation (EC) No 1223/2009.

Practical tip:

Ask:

“Can the CPSR be completed using SDS, my formula, and publicly available toxicological data?”

 

Red Flags, Low-Cost Assessors, and Practical Guidance

Indicators to consider when evaluating CPSR assessors:

  • Assessors who request that suppliers provide IFRA certificates, Certificates of Analysis (CoA), allergen declarations, or Annex VIII / PCN composition data for raw fragrance materials, where such documentation may not typically be available.

  • Off-the-shelf or generic CPSR services that indicate they can prepare assessments without reviewing SDS or fully understanding the specific raw materials involved.

  • Assessors with limited familiarity with UVCB substances or naturally derived ingredients, who may approach raw materials in the same way as finished fragrance compositions.

  • Requests for additional documentation or supplier engagement beyond what is legally required, which may lead to delays or unnecessary complexity.

  • Lack of clearly demonstrated qualifications in cosmetic toxicology or regulatory compliance.

  • Limited transparency regarding credentials, experience, or methodology (e.g. freelance profiles without references or standardised assessment packages).

  • Inability to clearly reference the legislative basis when stating that additional documentation is required.

  • Limited explanation of how the CPSR will be completed using SDS, formulation data, and publicly available toxicological information.

 

 

Price Guidance & Low-Cost CPSR Pitfalls

When selecting a CPSR service, it is important to consider scope and competency alongside cost. Lower-cost or off-the-shelf assessments may be suitable in some contexts, but in other cases they may be based on standardised approaches more commonly applied to finished fragrance oils rather than raw fragrance materials.

In such cases, assessors may request documentation such as IFRA certificates, CoA, or allergen statements, not because these are always legally required, but because their assessment process relies on predefined inputs.

To ensure alignment, it is advisable to ask:

“Can the CPSR be completed using the SDS, my formulation, and publicly available toxicological information?”

Engaging an assessor who can clearly explain their methodology and demonstrate appropriate qualifications (e.g. RSC or BTS membership) can help avoid delays and ensure a robust, compliant assessment.

 

 

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 SDS availability

  • Engage a qualified assessor

  • Retain documentation

  • Accept supplier limitations

  • Avoid informal reliance

Failure to do so risks non-compliance.

 

Common Misconceptions

“I need IFRA for all raw materials”

→ Not legally required

“I must have CoA”

→ Not required under law

“Suppliers must provide allergen data”

→ Only required at finished product level

“SDS are insufficient”

→ Incorrect when used by qualified assessors

“My assessor says it’s required, so it must be”

→ Must be justified in legislation

“Cheap CPSRs are fine”

→ Often template-based and limited

Real-world example 1:

An assessor refuses to proceed without IFRA for raw materials → delays project unnecessarily

Real-world example 2:

Low-cost CPSR provider demands CoA for all ingredients → supplier cannot provide → project stalls

 

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 carefully

  • Understand documentation limits

  • Engage qualified assessors early

  • Avoid off-the-shelf CPSRs

  • Conduct due diligence

 

References & Further Reading

 

Perfume Extract

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