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The General Product Safety REGULATION (GPSR) EU 2023/988 repeals the former “General Product Safety DIRECTIVE 2001/95/EC”, and lays down essential rules on the safety of consumer products placed on or made available on the EU market.
The EU GPSR applies to many consumer product categories including cosmetics. However, many product categories have been less strictly regulated on many aspects when compared to cosmetics. The EU GPSR raises the bar for these product categories up to the level that to a large degree is already in place for cosmetics with the Cosmetic Products Regulation (CPR).
There are additional requirements in online sales that go beyond, or at least specify, the requirements under the Cosmetic Products Regulation (CPR). These are related to the information that is shown online on the individual product sales page.
There is NO impact on the areas already covered by the CPR such as the cosmetics PIF requirements, regulatory compliance and safety assessment of cosmetics, cosmetics label content, cosmetic claims, CPNP notifications, etc.
The objective of the EU GPSR is to improve traceability for authorities to easily identify and contact the EU RP, and to ensure the communication of safety-related consumer information of products sold over the internet in the EU (e.g. your own/distributor web shop, Amazon, Sephora, Douglas, etc.). There are 3 additional information requirements for cosmetics in online sales on the individual product page:
The EU GPSR allows for all information to be communicated online by uploading up-to-date clearly legible product and/or label images on the individual product page that contain all required information.
However, it may be unpractical or impossible to upload multiple and sufficiently clearly legible images on the product page in all online sales channels. Also keep in mind that the information and therefor the images have to be up-to-date at all times.
An alternative or in addition to product and/or label images is to include (part of) the stated additionally required information in editable fields on the individual product pages.
To meet these requirements, it is important to organise your images and/or your information, to place the information on the sales websites that are under your own control, and to share the information down the supply chain to other online sales channels on request.
ADVICE: To prevent unwanted phone and/or email traffic from consumers with questions about matters that have nothing to do with compliance DO NOT put physical address details, email addresses and phone numbers online. Placing email addresses online will also result in increased email spam messages.
ADVICE: When placing the additionally required information online, make clear that this information is only relevant to and to be used by competent EU and member state authorities. For example, by including a statement that these Responsible Person details are “For authorities only”.
These requirements apply from DECEMBER 13, 2024.
One of the objectives of the EU GPSR is to improve traceability for authorities and to ensure the communication of safety-related consumer information of products sold over the internet in the EU.
The impact for cosmetics, when product compliance and safety is currently properly managed, is limited and mostly administrative.
Nevertheless, it is important to get organised and meet the additional requirements before December 13, 2024. Make sure to place only the minimum required additional information online.