Soap and Cosmetics Safety Assessments: What UK Makers Need to Know

If you make soap, bath bombs, lip balms, moisturisers, or any product applied to the body, UK law requires a Cosmetic Product Safety Report (CPSR) before you can sell it. No CPSR, no legal sale — it's that straightforward.

This guide explains what a CPSR is, which products need one, how to prepare for the assessment, and what happens after you have it.

This covers GB cosmetic product requirements. Northern Ireland follows EU Cosmetics Regulation, which differs in some details. This is not legal advice.

What Is a CPSR?

A Cosmetic Product Safety Report is a formal document, prepared and signed by a qualified safety assessor, that confirms your product is safe for its intended cosmetic use. It's required by Regulation (EC) No 1223/2009 on cosmetic products, which is retained in UK law.

The CPSR has two parts:

Part A — Cosmetic Product Safety Information: This compiles the product's quantitative and qualitative composition, physical/chemical characteristics, microbiological quality, impurities, packaging information, normal and reasonably foreseeable use, exposure assessment, and toxicological profiles of the ingredients.

Part B — Cosmetic Product Safety Assessment: The qualified safety assessor evaluates the Part A information and issues a professional judgement on whether the product is safe. This is the part that requires a qualified assessor — you cannot write it yourself.

Which Products Need a CPSR?

The UK Cosmetics Regulation defines a cosmetic product as "any substance or mixture intended to be placed in contact with the external parts of the human body or with the teeth and the mucous membranes of the oral cavity, with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours."

Products that need a CPSR:

• Handmade soap (bar soap, liquid soap, soap bars with exfoliants)
• Bath bombs and bath salts
• Lip balms and lip scrubs
• Moisturisers, body butters, body oils
• Shampoo, conditioner, hair masks
• Shaving soap and shaving cream
• Deodorant
• Toothpaste and mouthwash
• Face masks, serums, cleansers
• Perfume and eau de toilette applied to skin

Products that do NOT need a CPSR (but may need CLP labels instead):

• Scented candles — not applied to the body; fall under CLP regulations
• Wax melts, reed diffusers, room sprays — ambient fragrance products, regulated under CLP
• Cleaning products — not cosmetics even if they contain fragrance

If you sell both home fragrance products and body care products, you're dealing with two separate regulatory regimes: CLP for the fragrances, Cosmetics Regulation for the body care. Each has different requirements.

The SCPN Notification

Having a CPSR is not enough on its own. Before placing a cosmetic product on the GB market, you must also submit a notification through the SCPN (Submit Cosmetic Product Notifications) service. This is a free government service — you register as a responsible person and submit product details for each cosmetic you sell.

The notification requires:

• Product category and name
• The responsible person's details (your business name and UK address)
• Country of origin
• The product's function
• Your complete formulation (frame formulation format)
• The CPSR itself

You must notify before placing the product on the market. Selling without notification is a criminal offence.

What Does a CPSR Cost?

Costs vary widely depending on the assessor, the product complexity, and how much preparation you've done. Simple products (e.g., a cold-process soap with a short ingredient list) tend to cost less than complex multi-ingredient formulations.

When comparing quotes, check what's included:

• Part A + Part B? Some assessors quote for Part B only and expect you to compile Part A yourself
• Number of products covered? Some offer batch pricing for product ranges
• Reformulation updates? Check whether minor formulation changes require a full re-assessment or a lower-cost amendment
• Turnaround time? Standard turnaround is typically a few weeks; rush services cost more

How to Prepare for a CPSR

The better your preparation, the faster and cheaper the assessment. Here's what you'll need before approaching an assessor:

1. Complete ingredient list with INCI names Every ingredient must be listed using its International Nomenclature of Cosmetic Ingredients (INCI) name. Your ingredient suppliers should provide these. "Lavender oil" is not sufficient — you need "Lavandula Angustifolia Oil" or the appropriate INCI designation.

2. Quantitative formulation The exact percentage of each ingredient in the finished product. The assessor needs this to evaluate safety at the concentrations used.

3. Safety Data Sheets for each ingredient Current SDS documents from your suppliers. These provide the toxicological data the assessor needs for Part A.

4. Manufacturing process description How the product is made — cold process, hot process, melt and pour, etc. The manufacturing method affects safety considerations like pH levels and microbial risk.

5. Stability and challenge test results (where applicable) Products containing water or that are exposed to water (liquid soap, moisturisers, bath products stored wet) typically need preservative efficacy testing (challenge testing) to demonstrate they resist microbial contamination. Anhydrous products (solid soap, lip balm with no water) may not need this, but confirm with your assessor.

6. Intended use and target audience How the product is used, how often, and on which parts of the body. A hand soap has different exposure characteristics than a leave-on face cream.

After the CPSR: Ongoing Requirements

The CPSR is not a one-off tick-box. You have ongoing obligations:

Product Information File (PIF): You must maintain a PIF for each cosmetic product. The PIF contains the CPSR, product description, manufacturing method, proof of the claimed effect, and animal testing data (where relevant). The PIF must be kept for 10 years after the last batch is placed on the market and made available to enforcement authorities on request.

Labelling requirements: Cosmetic labels have their own requirements separate from CLP — including the product function, ingredient list (in INCI format), best-before date or PAO (period after opening) symbol, batch number, and the responsible person's details. Use our free Cosmetic Labelling Checker to verify your labels include all required elements.

Reformulation updates: If you change any ingredient or concentration, assess whether the CPSR needs updating. Significant changes typically require a reassessment.

Adverse event reporting: If you become aware of a serious undesirable effect from your product, you must report it to the Office for Product Safety and Standards (OPSS).

Penalties for Non-Compliance

Selling cosmetic products without a CPSR or SCPN notification is a criminal offence under the Cosmetic Products Enforcement Regulations 2013. Penalties can include fines and imprisonment. Trading standards officers enforce these regulations and can seize products, issue improvement notices, and prosecute.

Online marketplaces are also increasing compliance checks. Etsy and Amazon may require evidence of cosmetic compliance before allowing listings in regulated categories.

Sources

• GOV.UK — Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (Great Britain)
• GOV.UK — Making Cosmetic Products Available to Consumers in Great Britain
• GOV.UK — Submit a Cosmetic Product Notification
• GOV.UK — Consumer Products: Cosmetics