• Fran Bullen

The Cost of Compliance? A blog for cosmetic manufacturers

Updated: Jun 1, 2020

A lot of the smaller cosmetic manufacturers question the cost of getting their products

notified on the EU portal (and thereby complying with EU Regulation (EC) N° 1223/2009).

When they come to us for more information about this, it’s not uncommon for them to reply that the costs are far too expensive and they know people who’ve sold cosmetics for years and never had to bother with regulations.

On the other hand, we also hear from small manufacturers who are keen to register their products properly; so that they can take advantage of selling their products openly and without the worry of being found in contravention of EU law. This also lets them take advantage of the wide range of marketing strategies available to today’s small businesses, for example:

● Website marketing

● Listing products on specialist selling sites such as Etsy and Ebay

● Setting up stalls at local Fairs and Farmers Markets,

- all without having to look over their shoulder in case they’re being watched by Trading Standards – the body tasked with ensuring all cosmetic manufacturers are selling legitimate products.

Granted, Trading Standards is a busy operation and it relies on word of mouth to alert it to

companies selling goods illegally. However, as anyone can call Trading Standards to pass on such information, cosmetic manufacturers that haven’t complied with EU regulations are at risk of being informed on by rival manufacturers or unhappy competitors who’ve invested in achieving compliance and aren’t happy that they’re competitors haven’t. There’s another risk with non-compliance too – the chance that a product could actually cause some harm to a customer, and without the correct paperwork in place to show the product was manufactured following the correct guidelines, it is unlikely that any legal action on the part of the customer would be covered by any insurance on the behalf of the manufacturer. Plus, Trading Standards is more likely to consider pressing for either a custodial sentence in this instance or at the very least a hefty fine.

So, what we’re really talking about here is an imbalance between the cost of compliance and the cost of non-compliance; where the cost of compliance allows companies to trade openly and market their products professionally and the cost of non-compliance puts individuals at risk of prosecution or at the very least, a formal warning and a criminal record.

When you’ve invested time, energy and funds into preparing your cosmetic products, why waste it by not registering them properly? As the initial cost of complying with EU Regulations can be efficiently offset by the increase in income from the extra exposure you can give your products through innovative marketing. It makes sense to take it seriously.

In order to notify a cosmetic product on the European Portal you will need the following information as well as a Responsible Person for the product (the Responsible Person can be a company):

● an INCI list of the ingredients used in the product with a % breakdown (in PDF


● images of the label and the product in its packaging (in JPEG format)

● correct labelling for the packaging of the product

● you need to be registered as a company or an individual on the Portal

Verdigris Cosmetic Solutions Ltd

June 2019

BLOGS COMING SOON: Cosmetic Product Safety Reports (CPSRs)

Good Manufacturing Practice (GMP)

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