You make soap in your kitchen, blend balms in a small studio or sell creams at local markets. The question every small producer asks sooner or later: do handmade and small-batch cosmetics need a CPSR? The short answer is yes. This guide explains why size does not change the rules, what you need to do and how to keep the cost manageable for a small business.
Contents
- The short answer
- What counts as “placing on the market”?
- Why small producers are not exempt
- The six must-haves for a small-batch cosmetic
- Good manufacturing practice at home
- Which tests do small producers usually need?
- Handmade soap: a special case
- How to keep the cost down
- Common mistakes of small producers
- Selling on Etsy and online marketplaces
- A simple starting plan
- Example: a market-stall seller
- Insurance and liability
- Keeping records
- When your business grows
- Free samples, gifts and events
- Where to start if you already sell
- Frequently asked questions
- Key takeaways
The short answer
Yes. The EU Cosmetics Regulation (EC) No 1223/2009 applies to every cosmetic product placed on the market, whatever the size of the company or the batch. Handmade, artisan and homemade products are not exempt. Before you sell, or even give a product away as part of a business activity, a qualified safety assessor must produce a Cosmetic Product Safety Report for it.
What counts as “placing on the market”?
The Regulation speaks of supplying a product for distribution, consumption or use on the EU market in the course of a commercial activity, with or without payment. That covers:
- selling online, in a shop or at a market stall
- selling through marketplaces and social media
- giving products to customers, influencers or as promotional samples as part of a business
Making soap for your own family is private use and not covered. The moment you sell or supply products commercially, the rules apply.
Read also How to Sell Handmade Cosmetics Legally: Soap, Balms and Creams
Why small producers are not exempt
Safety risks do not depend on batch size. A contaminated lotion or an irritating ingredient is equally harmful whether 20 or 20,000 units were made. Handmade products can even carry higher risks, because home production lacks the controls of a factory, and recipes found online may use ingredients above their legal limits.
The six must-haves for a small-batch cosmetic
- A compliant formula. Every ingredient must be allowed, within its limits, according to the annexes of the Regulation.
- A Responsible Person in the EU. You can be your own Responsible Person if your business is established in the EU.
- A CPSR. Prepared and signed by a qualified safety assessor.
- A Product Information File (PIF). Held for ten years after the last batch is placed on the market.
- Correct labelling. Name and address, ingredients in INCI, batch number, period after opening or minimum durability, and warnings.
- A CPNP notification. Free of charge, completed before the product is sold.
Good manufacturing practice at home
The Regulation requires production according to good manufacturing practice. For a small business this means a clean, dedicated workspace, calibrated scales, clean equipment, written recipes with batch records and hygiene rules for people and water. You do not need a certified factory, but you do need to be able to show how you work.
Read also Private Label Cosmetics CPSR: What Brands Must Do
Which tests do small producers usually need?
- A stability and compatibility test to set the shelf life and check the packaging.
- A microbiological specifications test to confirm the product is clean.
- A challenge test for anything containing water, such as creams, lotions and serums.
Products with no water, such as many solid balms, oils and some soaps, are often lower risk. Your safety assessor will decide what is needed, so check before you buy any test.
Handmade soap: a special case
Soap is a cosmetic when it is intended for cleaning the skin. Cold-process soap has a high pH and little free water, which lowers its microbial risk, but the full CPSR, PIF, labelling and notification still apply. Watch out for fragrance and essential oils, which bring declarable allergens, and for colourants, which must appear in the permitted lists.
How to keep the cost down
- Keep the formula simple. Fewer ingredients put you in a lower CPSR tier. Our Simple tier covers up to 10 ingredients.
- Standardise your base. Variants on the same base may be assessed together.
- Finalise before ordering. Changes after the report mean rework.
- Bundle tests with the CPSR. One pickup and a complete file. Create a free account to unlock 10% off your first order and 20% on bundles.
Read also Cosmetic Testing for Small Business and Startups: A Lean Plan
Common mistakes of small producers
- using an online recipe without checking ingredient limits
- relying on “natural” to avoid testing
- selling first and planning the paperwork later
- forgetting that free samples count
- changing the recipe without updating the report
- making claims such as “hypoallergenic” without evidence
Selling on Etsy and online marketplaces
Marketplaces apply the same law. Many ask for a Responsible Person, a CPNP number or a safety report when a listing is reviewed. Prepare your documents before you publish a listing, so you are not forced to pause sales later.
A simple starting plan
- Week 1: finalise the recipe and check every ingredient against the annexes.
- Week 1–2: send samples for stability, microbiological and, if needed, challenge tests.
- Weeks 3–6: complete the CPSR and PIF, prepare the label.
- Before the first sale: notify the product in the CPNP.
Example: a market-stall seller
A seller makes whipped body butter and sells it on a weekend market. The product has no water, so the risk is lower, but the seller still needs the formula checked against the annexes, a CPSR, a Product Information File, a compliant label and a CPNP notification. The microbiological test is a low-cost way to show the product is clean, and the assessor confirms whether a challenge test is needed.
Insurance and liability
A complete safety file also protects you. Product liability insurers often ask for the CPSR, and if a customer reports a reaction you can show that the product was assessed by a qualified person. Without the file, you carry the full burden of proof yourself.
Keeping records
Record every batch: date, quantity, ingredient lot numbers and who made it. This helps with traceability, and it satisfies the good manufacturing practice requirement. A simple spreadsheet and a labelled folder for each product are enough at small scale.
When your business grows
The same documents scale with you. As volumes grow, you can move production to a contract manufacturer with ISO 22716 certification, keep the same formula and reuse the safety file, as long as the formula and packaging stay the same. Any changes need an update to the report.
Free samples, gifts and events
Handing out samples at an event, sending products to bloggers or including a trial size in an order are all forms of supply in the course of a business. The same rules apply, so the product needs its safety assessment, correct labelling and a notification even if no money changes hands. Plan the samples as part of the original compliance work.
Where to start if you already sell
If you are already selling products without the paperwork, do not panic, but act. Stop adding new batches, assemble your formulas and start with the best-selling product. A safety assessor can usually tell you quickly what is missing and in which order to fix it, and it is far cheaper to do it now than after a complaint or an inspection.
Frequently asked questions
Is there a small-business exemption?
No. The Regulation contains no exemption based on the size of the company or batch.
Can I be my own Responsible Person?
Yes, if your company is established in the EU and you can meet the obligations. Otherwise appoint a service provider.
Do I need a CPSR for each scent or colour?
Each formula needs assessing. Closely related variants may be covered together if the assessor can justify it.
Key takeaways
- Handmade and small-batch cosmetics need a CPSR as much as any other product.
- The rules apply as soon as you sell or supply a product commercially, including free samples.
- Simple formulas and bundled tests keep costs low.
- Do the paperwork before the first sale.