When Does a CPSR Need to Be Updated?

You signed off your safety report, launched the product and moved on. Then a supplier changes a raw material, a new ingredient restriction is published or a customer reports a reaction. Do you need to update your CPSR? In many cases the answer is yes. This guide explains what triggers an update, what the law says about keeping the report current and how to handle changes without delaying your sales.

The short answer

Yes: the cosmetic product safety report (CPSR) must be kept up to date. Annex I of Regulation (EC) No 1223/2009 requires it to be updated in view of additional relevant information generated after the product is placed on the market. The regulation does not set a fixed renewal date, such as every year or every three years. Instead, you update it when something relevant changes: the formula, the ingredient rules, the packaging, the use of the product, new safety data or new undesirable effects. The responsible person is accountable for that, and a qualified safety assessor should review and sign the new version.

Why does the CPSR have to stay current?

The CPSR is a snapshot of the safety assessment at a specific point in time. It is based on the formula, the exposure, the quality data and the scientific knowledge available on that day. All of these move. Ingredients are re-evaluated, limits are tightened, and real-world use shows what laboratory data could not. A report that no longer reflects the product on sale does not prove safety. During an inspection, an outdated CPSR can lead to the same consequences as a missing one. The product information file also has to be kept for ten years after the last batch is placed on the market, so the history of versions matters.

Read also How Much Does a CPSR Cost in 2026? Price Factors Explained

Changes to the formula

This is the most obvious trigger. Any of these normally calls for a review:

• A new ingredient, or removing one.
• A change in the concentration of an ingredient, including preservatives, UV filters, colourants and fragrance.
• A different supplier or grade of a raw material, if the specification, purity or impurity profile changes.
• A new fragrance or a change of the fragrance composition.
• A change of the manufacturing process, for example a different temperature or a new mixing technique, that may affect stability or microbial quality.

The assessor decides whether the change is small enough to document in an addendum or large enough to need a full re-assessment. Do not decide that yourself, because even small changes in a preservative can alter the risk.

Changes in the law and in scientific opinions

EU ingredient rules are amended regularly through the annexes. New bans, restrictions and limits arrive in amending regulations (the so-called Omnibus acts), and the SCCS publishes opinions that change how a substance is judged. Newer examples are the rules on fragrance allergens in Regulation (EU) 2023/1545, which phase in labelling and restrictions for more allergens over several dates, and Omnibus VIII, which adds substances to the restricted and prohibited lists. When a substance in your formula is affected, check the transition dates, update the safety assessment and often the label as well. We recommend a standing calendar entry to check the annexes at least twice a year.

Changes to packaging

The CPSR contains information on the packaging material in contact with the product and any relevant migration or compatibility aspects. A change from glass to plastic, a new pump, a different inner coating or a new supplier of the tube can alter stability, preservation or leaching. Update the report, and repeat the stability and compatibility test if the new packaging is different in a relevant way.

Read also What Is a CPSR? Cosmetic Product Safety Report Explained

New data on safety, stability and microbiology

New test results belong in the file. If a later stability test shows a shorter shelf life, if a challenge test on a changed formula fails, or if a microbiological specifications test shows contamination in a batch, the assessor needs to see it. In the same way, a patch test or other human tolerance study should be added when it becomes available. Positive results strengthen the report; negative ones may require changes to the formula, preservation or label.

Serious undesirable effects and complaints

Data on undesirable effects, including serious undesirable effects, is part of the safety report. If your complaint log shows a pattern, such as repeated skin reactions linked to one batch or ingredient, update the assessment and consider corrective action. A serious case that you notify to the authority should also feed back into the report. Review your complaint records at regular intervals, not just when something goes wrong.

Changes to claims, target group and use

If you start to market a product for a new group (for example children or very sensitive skin), a new body area (around the eyes) or a new way of use, the exposure assumptions change. The same applies to a new product format, such as a spray instead of a cream, where inhalation exposure needs to be considered. New claims also need substantiation in the product file, although they sit outside the CPSR itself. If the intended use changes, ask the assessor to review before the new version goes on sale.

Read also SDS vs CPSR: Which One Do You Need?

What does an update involve in practice?

Updates are normally quicker than a first CPSR, because the assessor builds on the existing file. A typical sequence is:

1. Record the change: what changed, when and why, with documents from the supplier or manufacturer.
2. Send it to the assessor: with the old report and the new formula, specification or packaging data.
3. Gap check: the assessor decides which parts of Part A and Part B are affected.
4. New tests if needed: for example stability, microbiology or challenge tests.
5. Updated and signed CPSR: with a version number and date.
6. Update the product information file and, if necessary, the label and the CPNP notification.

Keep a simple change log with version numbers. It shows an inspector that your system works.

Practical habits that make updates easy

• Keep a controlled formula sheet and require that any change goes through one person.
• Ask suppliers to inform you before they change a raw material.
• Calendar a twice-yearly review of the EU annexes and your products.
• Store test reports by batch and date.
• Agree a turnaround with your assessor so that updates do not hold up production.

If you need a new CPSR or an updated version, we prepare it with a qualified safety assessor, typically about ten business days after we receive complete data.

Frequently asked questions

Does the CPSR expire after a set number of years?

The regulation does not state an expiry date. What matters is that it reflects the product as marketed and the current knowledge. Some brands review every product once a year as good practice.

Do I need a new CPSR when I only change the label design?

Not if only the graphics change. If the ingredient list, warnings, claims or functions change, the safety file and label need review.

Do I need to notify CPNP again after an update?

Only if the information in the notification changes, for example the formulation category or the nanomaterials information. Your responsible person should check the notification after every change.

Key takeaways

• The CPSR has to be kept up to date; there is no fixed renewal date, so changes trigger the review.
• Typical triggers are formula, supplier, law, packaging, new test data, complaints and changes of use.
• Let a qualified safety assessor decide how big an update is needed and sign the new version.
• Keep a change log and review EU ingredient annexes regularly.