What does a brand need to sell private label cosmetics in the EU?

Who is legally responsible for a private label cosmetic in the EU?

The brand. Regulation (EC) No 1223/2009, Article 2(1)(d) defines the manufacturer as "any natural or legal person who manufactures a cosmetic product or has such a product designed or manufactured" and markets it under its name or trademark. A brand established in the EU is therefore the Responsible Person for its own product, unless it mandates someone else.

Only a person established in the EU can hold that role. Article 4(1) allows on the market only "cosmetic products for which a legal or natural person is designated within the Community", and Article 4(3) says "the manufacturer established within the Community shall be the responsible person". The table shows who it is in each situation.

A factory can be your Responsible Person, but only through your written mandate and its written acceptance. Without that, the notification, the files and the answers to the authorities stay with your brand. The same question for other product groups is in is my brand legally the manufacturer.

What has to be done before the first unit is sold?

Three things, all for the Responsible Person: a safety report (Article 10), a product information file (Article 11) and a notification to the Commission through CPNP "prior to placing the cosmetic product on the market" (Article 13). The European Commission calls CPNP a "free online notification system for submitting information about cosmetic products placed on the EU market."

1. Safety report. Before the product is placed on the market, a safety assessment is carried out and a cosmetic product safety report is set up under Annex I (Article 10). The assessor must hold "a diploma or other evidence of formal qualifications" from a university course in pharmacy, toxicology, medicine or a similar discipline, or a course a Member State recognises as equivalent.
2. Product information file. The Responsible Person "shall keep a product information file" for each product, for ten years after the last batch is placed on the market (Article 11). It holds a description of the product, the safety report, a description of the method of manufacturing, proof of any effect claimed and data on animal testing, readily accessible to the authorities in a language they easily understand.
3. CPNP notification. Before the product goes on sale, the Responsible Person submits its category and name, its own name and the address where the file is kept, the country of origin of an imported product, the Member State where it will be placed on the market, a contact person, any nanomaterials and classified substances such as carcinogens by name and CAS or EC number (Article 13(1)), and the original labelling (Article 13(2)).
4. Changes. The notification is updated "without delay" when the information changes (Article 13(7)).

The notification itself is free. Sweden's Medical Products Agency (Läkemedelsverket) answers the question the same way: "Detta kostar inget." (This costs nothing.) It adds that Swedish companies notified in CPNP pay the agency an annual fee (Läkemedelsverket). Articles 10, 11 and 13 are quoted as adopted in 2009 and may have been amended since; check the current text on EUR-Lex.

Does the factory need good manufacturing practice or an ISO 22716 certificate?

The Regulation requires the practice, not a certificate. Article 8 says "the manufacture of cosmetic products shall comply with good manufacturing practice" (GMP), and compliance "shall be presumed where the manufacture is in accordance" with harmonised standards published in the Official Journal. The Commission lists EN ISO 22716:2007 as that standard.

The Commission's list of harmonised standards names "EN ISO 22716:2007", the GMP guidelines for cosmetics, and notes that only publication in the Official Journal has legal effect. Your product information file must also describe the method of manufacturing (Article 11(2)), so the factory has to give you that description. A certificate to ISO 22716 is one way it can show that it follows GMP; which certificates manufacturers name, and how to check them, is in the certificates guide.

What must a cosmetic label say?

Seven particulars, under Article 19(1), in lettering the article calls "indelible, easily legible and visible": the Responsible Person's name and address, nominal content, the date of minimum durability or period after opening, precautions, batch number, function and an ingredient list. The table gives each with its point and the national language rule.

The language is set nationally. Article 19(5) says it "shall be determined by the law of the Member States in which the product is made available to the end user." An effect you claim on the label needs "proof of the effect claimed for the cosmetic product" in the product information file (Article 11(2)).

Which language and which authority apply in each of the five countries?

Each country sets its label language and supervises its own market; in the Commission's words, "EU countries are responsible for the surveillance of their own markets for cosmetics." Latvia, Estonia and Sweden require their national language for content, durability, precautions and function. For Lithuania and Finland we have not confirmed the rule from an official page.

Sweden's ordinance states it directly: "Information enligt artikel 19.1 b, c, d och f i förordning (EG) nr 1223/2009 ska anges på svenska" (SFS 2013:413, 4 §). Latvia's rule is worded the same way for the state language, and Terviseamet writes that "Eestikeelne märgistus peab sisaldama vähemalt järgmist teavet" (the Estonian labelling must contain at least the following information). A pack sold in all three countries therefore carries those particulars in Latvian, Estonian and Swedish.

Which cosmetics rules change between 2025 and 2028?

Four dates fall in this window. Cosmetics containing TPO (trimethylbenzoyl diphenylphosphine oxide) have been banned since 1 September 2025. Since 31 July 2026, new products must label 56 more fragrance allergens individually. The transition for rinse-off cosmetics with intentionally added microplastics ends on 16 October 2027, and products with old allergen labels must leave shops after 31 July 2028.

On TPO, the Commission leaves no room: "From 1 September 2025, both placing and making available on the market of cosmetic products containing TPO are prohibited." For allergens, products placed on the market before 31 July 2026 "may continue to be made available on the EU market until 31 July 2028" (Commission). The microplastics dates are on the Commission's restriction page.

The Commission's list of cosmetics legislation names Regulation (EU) 2026/909; we have not confirmed its transition dates from the Official Journal, so they are not given here. The Commission's page on CMR substances tracks the acts on substances classified as carcinogenic, mutagenic or toxic for reproduction. For Omnibus VI, Fendler Salva wrote that the deal "must now be approved by the European Parliament and the Council", and Coptis still described it as pending on 8 October 2026.

Which cosmetics manufacturers say they help with the regulatory work?

6 of the 75 cosmetics manufacturers NordSourced lists in the five countries say on their own website that they take on part of the regulatory work: CPNP or market registration, safety assessment, documentation for sale or label compliance. Their own sentence is in the table. Under Article 4(3) a manufacturer acts as your Responsible Person only by your written mandate.

What each offers differs, from CPNP registration and the safety report to documentation for sale. Ask which of the steps above the manufacturer does, who signs the safety report, and whose name goes on the label as the Responsible Person. Other product groups are covered in manufacturers that help with the regulatory work.

Questions and answers

Where to go next

• Private label cosmetics manufacturers in the Baltics and the Nordics
• Private label cosmetics manufacturers in the Baltics
• Private label cosmetics manufacturers in the Nordics
• Is my brand legally the manufacturer when someone else makes the product?
• Which manufacturers in Northern Europe help with the regulatory work?
• Which certificates do private label manufacturers hold?
• Send a brief: we ask the manufacturers you approve, without your name

Sources

1. Regulation (EC) No 1223/2009 on cosmetic products, Articles 2, 4, 8, 10, 11, 13 and 19 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
2. Cosmetics: CPNP and the EU rules, European Commission. Checked 13 Oct 2026.
3. Harmonised standards for cosmetic products (EN ISO 22716:2007), European Commission. Checked 13 Oct 2026.
4. Market surveillance of cosmetics, European Commission. Checked 13 Oct 2026.
5. Fragrance allergens labelling, European Commission. Checked 13 Oct 2026.
6. Cosmetics legislation, European Commission. Checked 13 Oct 2026.
7. TPO in nail products: questions and answers, European Commission. Checked 13 Oct 2026.
8. CMR substances in cosmetic products, European Commission. Checked 13 Oct 2026.
9. Commission Regulation (EU) 2023/2055, restriction of intentionally added microplastics, European Commission. Checked 13 Oct 2026.
10. Ska man anmäla kosmetiska produkter någonstans?, Läkemedelsverket (Swedish Medical Products Agency). Checked 13 Oct 2026.
11. Cabinet Regulation No. 354 of 2 July 2013 on cosmetic products, Cabinet of Ministers of Latvia, via likumi.lv. Checked 13 Oct 2026.
12. Health Inspectorate of Latvia, Veselības inspekcija. Checked 13 Oct 2026.
13. Kosmeetikatooted, Terviseamet (Estonian Health Board). Checked 13 Oct 2026.
14. Kosmeetikatoodete märgistus, Terviseamet (Estonian Health Board). Checked 13 Oct 2026.
15. Förordning (2013:413) om kosmetiska produkter, Sveriges riksdag. Checked 13 Oct 2026.
16. Laki kosmeettisista valmisteista 492/2013, Finlex. Checked 13 Oct 2026.
17. Omnibus VI: provisional political agreement (23 June 2026; law firm commentary), Fendler Salva Partners. Checked 13 Oct 2026.
18. EU Omnibus VI and the Cosmetics Regulation (consultancy commentary), Coptis. Checked 13 Oct 2026.

Directory figures are counted from the manufacturers listed on NordSourced, each listed because its own website says it makes products for other brands; see how we check. This page is general information, not legal advice. Found a mistake? Tell us.