Product Information File: What UK Makers Keep
The Product Information File is the record you keep for every cosmetic you sell. It holds the safety report, the formulation and manufacturing detail, evidence for any claim you make, and animal-testing data — and it has to be kept for ten years after the last batch went on the market, at an address you already gave when you notified the product. It is not filed with anyone. It sits with you, and it has to be producible on request.
Most makers meet the PIF as a phrase in a compliance checklist and assume it is a form. It is not. It is a file you assemble and maintain, and the ten-year clock means it outlives the product.
This covers cosmetic products placed on the Great Britain market. This is not legal advice.
The Requirement
The duty is stated plainly:
"When a cosmetic product is placed on the market, the responsible person shall keep a product information file for it."
Per product — not per business, not per range. Six scents that differ in formulation are six files.
What Goes In It
Article 11(2) sets the contents:
- A description of the product. In the Regulation's words, "a description of the cosmetic product which enables the product information file to be clearly attributed to the cosmetic product". The point is unambiguous linkage: someone holding your product must be able to tell which file belongs to it.
- The Cosmetic Product Safety Report. The output of the assessment carried out by a qualified safety assessor.
- Manufacturing detail. "a description of the method of manufacturing and a statement on compliance with good manufacturing practice".
- Proof of claimed effects, "where justified by the nature or the effect of the cosmetic product". If you say a balm soothes, that claim needs support in the file.
- Animal-testing data, being "data on any animal testing performed by the manufacturer, their agents or suppliers, relating to the development or safety assessment of the cosmetic product or its ingredients".
The manufacturing-method requirement is the one makers most often under-do. A recipe is not a method — the file wants the process, the order, the temperatures, and the statement about good manufacturing practice, in enough detail that the batch could be reconstructed.
Where It Is Kept, and in What Form
Two operative requirements, and they connect the PIF to your SCPN notification:
"The responsible person must make the product information file readily accessible to a competent authority in an electronic or other format at the address notified in accordance with Article 13 as the address at which the product information file is kept."
"The information contained in the product information file must be in English."
Three things follow.
The address is not arbitrary. It is the address you gave in the notification as the place the PIF is kept. Move your records and the notified address is wrong.
"Readily accessible" is a real standard. Electronic format is expressly permitted, so a well-organised digital file is fine. What is not fine is a file that exists in principle but takes a fortnight to assemble from a shoebox, an inbox and three spreadsheets.
English. Supplier documentation that arrives in another language does not go into the file as-is.
Ten Years
The retention period:
"The product information file shall be kept for a period of ten years following the date on which the last batch of the cosmetic product was placed on the market."
Read the trigger carefully. The clock starts at the last batch, not at the first sale and not when you discontinue the product. A soap you made for four years and stopped selling in year four carries its file until year fourteen.
This is the practical case for keeping the PIF somewhere durable and backed up rather than on one laptop. Ten years is longer than most businesses keep the same computer, the same accounting software, or the same third-party service subscription — and if you use a paid Responsible Person service, check what happens to the file when that arrangement ends.
The Link to Batch Records
The PIF describes a product. Batch records tie an individual thing you sold back to that description. Neither is much use without the other.
If a complaint arrives about a specific bar, the question is which batch, made when, from which formulation version, and does that match the formulation the safety report covers. Answering that is what makes a targeted response possible rather than pulling everything. It is also, in practice, the point at which makers discover their formulation records were kept as a series of overwritten spreadsheets with no version history.
Our guide to cosmetic batch codes covers the coding side.
When the File Has to Change
The PIF describes the product as assessed. Anything that makes the description untrue points back at the file, and usually at the safety assessment behind it:
- Changing an ingredient or supplier
- Shifting percentages
- Changing the preservative system
- Altering the manufacturing method
- Adding a new claim to your marketing
That last one catches people. Adding "hydrating" to a product page is a claim, and the file is where the support for it lives.
Where It Sits in the Order
- Finalise the formulation.
- Commission the safety assessment — the report becomes part of the file.
- Establish the Responsible Person, who keeps the file.
- Assemble the PIF, at an address you can state.
- Notify through SCPN, giving that address.
- Label and sell.
Step 5 depends on step 4 having a real answer. Our SCPN guide covers the notification itself.
Common Questions
Do I submit the PIF to anyone?
No. You keep it. It is made available to a competent authority on request, at the notified address, in electronic or other format.
Is there a PIF template I can buy?
Templates exist and can be a reasonable starting structure. What a template cannot do is supply the contents — your safety report, your manufacturing method, your claim evidence. A well-organised file you assembled beats a purchased document with gaps in it.
How long do I keep the PIF?
Ten years from the date the last batch of that product was placed on the market — not ten years from first sale, and not from when you stopped selling it.
Does my candle or wax melt need a PIF?
No. The PIF is a cosmetics requirement. Candles, wax melts, diffusers and room sprays sit under GB CLP, which has its own record expectations rather than a PIF. See CLP versus cosmetics.
What if I sell in Northern Ireland?
This covers Great Britain. Northern Ireland follows EU cosmetics rules, and the notification and responsible-person arrangements differ. Check the NI position separately.
Related Guides
- SCPN: how to notify a cosmetic product UK
- Responsible Person for cosmetics: UK rules
- Soap and cosmetics safety assessments: what UK makers need to know
- Laws on selling homemade beauty products UK
CraftCert keeps formulations versioned and batch records attached to the products they made, on the CLP side of a mixed range. It does not produce a CPSR or hold your cosmetic PIF — those stay with you and your assessor. Our scope page sets out where the line falls.
Sources
Check Your Cosmetic Label
CraftCert covers CLP labelling for candles, wax melts, reed diffusers and home fragrance products, not cosmetics. For a cosmetic product, our free Cosmetic Labelling Checker walks you through the essential label elements the UK Cosmetics Regulation requires. You still need a CPSR from a qualified safety assessor before you sell.
Related Guides
Product Safety Rules for UK Craft Sellers
The General Product Safety Regulations 2005 sit under everything you sell. What the safety requirement says, the producer duties, and how they meet CLP.
Room Spray Labels: CLP Rules for UK Makers
What goes on a UK room spray label under GB CLP — when the hazard label is required, the elements it must carry, and the room-versus-body spray boundary.
Responsible Person for Cosmetics: UK Rules
Every UK cosmetic needs a Responsible Person established in the UK. What the role carries, who it falls on by default, and how appointing one works.