The (EU) General Product Safety Regulation (GPSR) has been recently updated to clarify the labelling required when selling online / distance selling. How does this affect cosmetic products?  In Article 19 of the Cosmetics Regulation EC1223/2009 (CPR), rules around labelling of cosmetic products are defined.

For cosmetic products sold online the following points are understood:

• The requirements apply regardless of whether a cosmetic product is sold online or through physical retail.
• For products sold online, the responsible person (RP) must be established in the EU/UK and have full product information and safety assessment available.
• Websites should clearly identify the responsible person and provide their address and contact information.
• Websites should not give the impression that requirements like safety assessments do not apply to cosmetic products offered online.
• Member state authorities have jurisdiction over products offered online to consumers on their territories. They can take action if products do not comply with CPR requirements.
• Authorities can use product images, listings, or labelling online to verify compliance even if products are not physically obtained.

Cosmetics Europe have provided additional information based on the update on the GPSR and the following are required on any website selling cosmetic products:

• Name, registered trade name or registered trademark of the manufacturer (RP), as well as the postal and electronic address (email or website) at which they can be contacted.
• Where the manufacturer is not established in the Union, the name, postal and electronic address (email or website) of the RP.
• Information showing the identification of the product, including a picture of it, its type and any other product identifier. If the picture of the product shows all the required information then it does not need to be written elsewhere on the web page. For example, if there is a photo of the pack showing the name, address, RP details, type / function and product name, then the listing will comply.
• Any warning or safety information to be in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market. If the picture of the product shows the required warnings or safety information, then it does not need to be written elsewhere on the web page.

What if a re-seller is selling your product on their website? It is the RP’s responsibility to provide all the required information to the re-seller. It is the re-seller’s / website owner’s responsibility to ensure the information is added to the listing, either with appropriate photos or separate text.

What if someone from a country not in the EU or UK wants to buy your product from your online shop? Different countries have different regulations and it would be the responsibility of the brand owner to ensure the product complies with the country’s specific regulations. It would also be wise to ensure there is insurance in place for all regions sold in to.

Guidance from Cosmetics Europe can be found here

These requirements are in addition to those in the CPR.  While this is for member states of the EU, this information is also useful for UK brand owners.