The Fitness Check of the EU Cosmetic Regulation
The European Commission has launched the Fitness Check of Regulation (EC) No 1223/2009 — the Cosmetic Products Regulation (EU CPR) that underpins cosmetic safety and market harmonization across the European Union. This evaluation follows the recent abandonment of the proposed revision of the EU CPR, reflecting the complexities and challenges regulators face in updating such a foundational framework. Instead of revising the regulation immediately, the Commission opted for this comprehensive review to assess whether the EU CPR remains effective, relevant, and fit for the future.
Why the Fitness Check Matters for the Cosmetics Industry
The EU CPR has served as the foundation for ensuring cosmetic product safety and smooth market access in Europe for over a decade. However, rapid developments in digital innovation, sustainability policies, animal testing alternatives, and e-commerce are reshaping the regulatory landscape.
For businesses, this fitness check could lead to updated rules that better accommodate small-scale producers, clarify labelling obligations, and improve alignment with other EU regulations such as REACH and CLP. For consumers, it ensures continued safety and transparency, especially as products increasingly move through online channels.
How the European Commission is Conducting the Fitness Check
The fitness check evaluates the EU CPR against five key criteria:
- Effectiveness: Does the EU CPR still ensure consumer safety and enable a functioning internal market for cosmetics?
- Efficiency: Are compliance and administrative costs proportionate to the regulation’s benefits?
- Relevance: Is the EU CPR compatible with current trends in digital technology, innovation, and green policies?
- Coherence: How well does the EU CPR align with related EU regulations such as REACH, CLP, medical device laws, and environmental sustainability frameworks?
- EU Added Value: Does harmonized EU legislation deliver more benefits compared to a patchwork of national rules?
This rigorous, evidence-based approach reflects the Commission’s commitment to Better Regulation principles.
Industry Feedback: Key Issues Raised by Stakeholders
During the first consultation phase (closed 21 March 2025), a broad range of industry voices shared their perspectives — from large manufacturers to artisan producers. Here are the main points that emerged:
1. Animal Testing and Non-Animal Methods (NAMs)
Animal testing remains a hot topic. Organizations such as Unilever, the Scientific Committee on Consumer Safety (SCCS), and animal welfare groups highlighted inconsistencies between the EU CPR and other frameworks like REACH. Many called for clearer recognition and promotion of Non-Animal Methods (NAMs), emphasizing the need for validated alternatives to animal testing in safety assessments.
2. Regulatory Equity for Small Businesses
Small enterprises and independent practitioners, particularly in aroma and fragrance sectors, stressed that the Product Information File (PIF) and safety assessment requirements are burdensome for small-batch or artisanal products. They requested more tailored approaches acknowledging limited resources without compromising safety.
3. Harmonization with REACH and CLP
Agencies like ANSES (the French Agency for Food, Environmental and Occupational Health & Safety) and associations such as FEBEA (the French Association of Cosmetic Industries) asked for clearer rules regarding how hazard classifications (e.g., carcinogenic, mutagenic, or reproductive toxicant — CMR — substances) under REACH and CLP affect cosmetic ingredients under the EU CPR. The current lack of transparency causes uncertainty and delays in product development.
4. Digital and Online Sales Challenges
As e-commerce grows, companies including Cosmed raised concerns about complex labelling requirements, particularly for online sales and bulk or packaging-free products. Stakeholders urge the Commission to address digital labelling solutions, adapt to smaller packaging constraints, and clarify online platform responsibilities.
5. Navigating Environmental Regulations
Industry groups like FEBEA highlighted challenges caused by the interaction between the EU CPR and new environmental regulations such as PPWR (Packaging Regulation), ESPR (Ecodesign Regulation), CS3D, and CSRD. They seek clearer guidance on sustainability reporting, packaging obligations, and managing overlapping regulatory demands.
6. Support for EU-wide Harmonization
Almost all respondents emphasized the importance of maintaining EU-wide rules to avoid market fragmentation. Organizations such as ICCS (International Collaboration on Cosmetic Safety) and ANSES warned that national divergences would undermine market stability and complicate compliance for companies operating in multiple member states.
The Public Consultation: Your Chance to Influence the EU Cosmetic Regulation
The fitness check’s second phase is a public consultation open until 28 July 2025. It invites input from:
- Consumers — on the safety and labelling of cosmetics sold online and offline.
- Industry professionals — on regulatory, environmental, and economic aspects of CPR compliance.
The survey covers topics including:
- Safety of cosmetics in the EU and imported products.
- Effectiveness and clarity of labelling (e.g., allergen disclosure, age restrictions).
- Alignment with environmental objectives like packaging waste reduction.
- Economic feasibility for businesses, especially SMEs, to comply with the EU CPR.
>> Participate in the EU Cosmetic Regulation Public Consultation
What’s Next? The Road Ahead for the EU Cosmetic Regulation
This fitness check arrives at a pivotal moment. The cosmetics industry faces rising sustainability expectations, digital disruption, and evolving consumer demands. While the EU CPR remains a regulatory cornerstone, stakeholders clearly signal that adjustments and clarifications will be necessary.
The Commission will analyze the consultation feedback and decide whether to revise the EU CPR or maintain it with enhanced guidance. The final decision is expected by the second quarter of 2026.
For companies, regulators, and consumers, this is a unique opportunity to shape the future of cosmetic regulation in Europe — ensuring that safety, innovation, and market stability go hand in hand.
If you would like to find out more about the regulatory requirements for cosmetic products, please do not hesitate to contact us by phone on +33 (0)1 83 64 20 54 or via our contact form.
The Fitness Check of the EU Cosmetic Regulation
The European Commission has launched the Fitness Check of Regulation (EC) No 1223/2009 — the Cosmetic Products Regulation (EU CPR) that underpins cosmetic safety and market harmonization across the European Union. This evaluation follows the recent abandonment of the proposed revision of the EU CPR, reflecting the complexities and challenges regulators face in updating such a foundational framework. Instead of revising the regulation immediately, the Commission opted for this comprehensive review to assess whether the EU CPR remains effective, relevant, and fit for the future.
Why the Fitness Check Matters for the Cosmetics Industry
The EU CPR has served as the foundation for ensuring cosmetic product safety and smooth market access in Europe for over a decade. However, rapid developments in digital innovation, sustainability policies, animal testing alternatives, and e-commerce are reshaping the regulatory landscape.
For businesses, this fitness check could lead to updated rules that better accommodate small-scale producers, clarify labelling obligations, and improve alignment with other EU regulations such as REACH and CLP. For consumers, it ensures continued safety and transparency, especially as products increasingly move through online channels.
How the European Commission is Conducting the Fitness Check
The fitness check evaluates the EU CPR against five key criteria:
- Effectiveness: Does the EU CPR still ensure consumer safety and enable a functioning internal market for cosmetics?
- Efficiency: Are compliance and administrative costs proportionate to the regulation’s benefits?
- Relevance: Is the EU CPR compatible with current trends in digital technology, innovation, and green policies?
- Coherence: How well does the EU CPR align with related EU regulations such as REACH, CLP, medical device laws, and environmental sustainability frameworks?
- EU Added Value: Does harmonized EU legislation deliver more benefits compared to a patchwork of national rules?
This rigorous, evidence-based approach reflects the Commission’s commitment to Better Regulation principles.
Industry Feedback: Key Issues Raised by Stakeholders
During the first consultation phase (closed 21 March 2025), a broad range of industry voices shared their perspectives — from large manufacturers to artisan producers. Here are the main points that emerged:
1. Animal Testing and Non-Animal Methods (NAMs)
Animal testing remains a hot topic. Organizations such as Unilever, the Scientific Committee on Consumer Safety (SCCS), and animal welfare groups highlighted inconsistencies between the EU CPR and other frameworks like REACH. Many called for clearer recognition and promotion of Non-Animal Methods (NAMs), emphasizing the need for validated alternatives to animal testing in safety assessments.
2. Regulatory Equity for Small Businesses
Small enterprises and independent practitioners, particularly in aroma and fragrance sectors, stressed that the Product Information File (PIF) and safety assessment requirements are burdensome for small-batch or artisanal products. They requested more tailored approaches acknowledging limited resources without compromising safety.
3. Harmonization with REACH and CLP
Agencies like ANSES (the French Agency for Food, Environmental and Occupational Health & Safety) and associations such as FEBEA (the French Association of Cosmetic Industries) asked for clearer rules regarding how hazard classifications (e.g., carcinogenic, mutagenic, or reproductive toxicant — CMR — substances) under REACH and CLP affect cosmetic ingredients under the EU CPR. The current lack of transparency causes uncertainty and delays in product development.
4. Digital and Online Sales Challenges
As e-commerce grows, companies including Cosmed raised concerns about complex labelling requirements, particularly for online sales and bulk or packaging-free products. Stakeholders urge the Commission to address digital labelling solutions, adapt to smaller packaging constraints, and clarify online platform responsibilities.
5. Navigating Environmental Regulations
Industry groups like FEBEA highlighted challenges caused by the interaction between the EU CPR and new environmental regulations such as PPWR (Packaging Regulation), ESPR (Ecodesign Regulation), CS3D, and CSRD. They seek clearer guidance on sustainability reporting, packaging obligations, and managing overlapping regulatory demands.
6. Support for EU-wide Harmonization
Almost all respondents emphasized the importance of maintaining EU-wide rules to avoid market fragmentation. Organizations such as ICCS (International Collaboration on Cosmetic Safety) and ANSES warned that national divergences would undermine market stability and complicate compliance for companies operating in multiple member states.
The Public Consultation: Your Chance to Influence the EU Cosmetic Regulation
The fitness check’s second phase is a public consultation open until 28 July 2025. It invites input from:
- Consumers — on the safety and labelling of cosmetics sold online and offline.
- Industry professionals — on regulatory, environmental, and economic aspects of CPR compliance.
The survey covers topics including:
- Safety of cosmetics in the EU and imported products.
- Effectiveness and clarity of labelling (e.g., allergen disclosure, age restrictions).
- Alignment with environmental objectives like packaging waste reduction.
- Economic feasibility for businesses, especially SMEs, to comply with the EU CPR.
>> Participate in the EU Cosmetic Regulation Public Consultation
What’s Next? The Road Ahead for the EU Cosmetic Regulation
This fitness check arrives at a pivotal moment. The cosmetics industry faces rising sustainability expectations, digital disruption, and evolving consumer demands. While the EU CPR remains a regulatory cornerstone, stakeholders clearly signal that adjustments and clarifications will be necessary.
The Commission will analyze the consultation feedback and decide whether to revise the EU CPR or maintain it with enhanced guidance. The final decision is expected by the second quarter of 2026.
For companies, regulators, and consumers, this is a unique opportunity to shape the future of cosmetic regulation in Europe — ensuring that safety, innovation, and market stability go hand in hand.
If you would like to find out more about the regulatory requirements for cosmetic products, please do not hesitate to contact us by phone on +33 (0)1 83 64 20 54 or via our contact form.
