Exporting Thai Cosmetics to the EU: Responsible Person, CPNP, Safety Report and Labels

Thai cosmetics, skincare and spa products — including private-label lines made by Thai OEM manufacturers — are increasingly sold in Europe. The European Union regulates cosmetics under Regulation (EC) No 1223/2009. Whether you are a brand owner importing finished goods or a Thai manufacturer exporting for a client, it helps to understand who is responsible for what before the first shipment.

1. The EU Responsible Person

Every cosmetic product placed on the EU market must have a Responsible Person (RP) established in the EU. The RP is legally responsible for the product's compliance. It is often the importing brand, a distributor, or a specialised regulatory service company. A Thai manufacturer cannot act as the RP from Thailand.

2. Product Information File and safety assessment

The RP must keep a Product Information File (PIF) for each product. Its core is the Cosmetic Product Safety Report (CPSR), prepared by a qualified safety assessor. The PIF typically includes:

• The full formula and ingredient information, including raw-material specifications.
• Stability and compatibility data, microbiological quality and, where relevant, preservative efficacy.
• Evidence supporting product claims.
• A description of the manufacturing method and a statement of GMP compliance.

Thai manufacturers usually need to provide much of this data, so agree early on which documents they will supply.

3. Ingredients that are restricted or banned

EU annexes list prohibited and restricted substances, approved colourants, preservatives and UV filters. A formula that is compliant in Thailand may still need changes for Europe — for example certain whitening agents, preservatives or fragrance allergens. Have the formula checked against the current EU annexes before you finalise packaging.

4. Good Manufacturing Practice

EU law requires cosmetics to be made under GMP. ISO 22716 is the recognised standard for cosmetics GMP. Ask your Thai manufacturer whether it holds ISO 22716 or equivalent and request a copy.

5. CPNP notification

Before the product is sold, the RP notifies it through the EU Cosmetic Products Notification Portal (CPNP). The United Kingdom runs its own separate notification system and Responsible Person requirement after Brexit.

6. Labelling

• Name and address of the Responsible Person.
• Nominal content, date of minimum durability or period-after-opening symbol.
• Precautions for use, batch number, function of the product where not obvious.
• Ingredient list using INCI names, including labelled fragrance allergens where required.
• Language requirements of each member state where the product is sold.

7. Animal testing

The EU bans animal testing for cosmetic products and ingredients and the marketing of products tested on animals for cosmetic purposes. Ask your supplier to confirm this in writing.

Practical sequence

1. Choose your EU Responsible Person and safety assessor.
2. Check the formula against EU annexes with your manufacturer.
3. Collect the documents for the PIF and complete the CPSR.
4. Finalise the EU label artwork, then notify in the CPNP.
5. Ship with batch documentation that matches the PIF.

This is a general overview, not legal advice — work with a qualified EU regulatory professional for your specific products.

Find Thai cosmetics manufacturers

Browse OEM cosmetics and skincare, skincare and beauty and personal care suppliers, or post a free RFQ that mentions you need EU-ready documentation. See also our Thai OEM cosmetics guide.