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CBD Cosmetic Registration – What You Need When Introducing CBD Cosmetic Products in The EU 

Are you planning to introduce a CBD cosmetic product in an EU market? There are several regulations you need to adhere to, including CBD cosmetic registration, cosmetic product notification portal (CPNP), and stability test. 

According to the Cosmetic Regulation 1223/2009, there are several obligations that every business must adhere to so that their cosmetic products are legally allowed to sell within the EU. These requirements include appointing a responsible person, creating a Product Information File, CPNP notification, and labelling compliance, among others.

The steps to successful CBD Cosmetic registration

The steps you need to follow are complex, but this guide tries to simplify them for you to get a general overview of what needs to be done. 

Step 1 – choosing a Responsible Person

The first step to successful CBD oil registration is choosing a Responsible Person (RP) for every cosmetic product introduced into the EU market. This can be a person, either legal or natural within the EU, including importers, distributors, or manufacturers.

The RP’s responsibilities include analysing product safety reports, compliance formulation, Product Information File, labelling, CPNP notification, and general information to the public, etc. 

Step 2 – Product composition review

This step involves validating the composition of your CBD cosmetic products before introducing them into the market. The cannabidiol products registration requires the cosmetic product formula to be reviewed against the regulation annexes. 

The Annexes of the Regulation is a detailed document, but at a glance, some of the things to look at include the raw materials, ingredients, and allergens.

Step 3 – creating Product Information File 

Preparing the Product Information File (PIF) is a mandatory process for CBD Cosmetic Registration. Regulatory authorities will request the PIF for all cosmetic products, including those that made entry before the regulation came into effect in 2013. 

The PIF is made available to the public for a period not less than 10 years by the RP, either in paper or electronic format. 

Step 4 – the creation of compliant labels 

When registering your CBD product into the EU market, your product label must also be compliant with the regulation. Some of the requirements of a label include:

  • RP’s name and address,
  • Product’s country of origin, 
  • Minimum durability date, 
  • Warning and precautions,
  • Batch number.
  • List of ingredients.
  • The purpose of the product.
  • Nominal content. 

Step 5 – CPNP Notification 

In this phase, the appointed Responsible Person will create the product notification through the CPNP portal. This is an online platform created for notification and enforcement of the 1223/2009 regulation by the EU.

CPNP notification is a mandatory requirement for your CBD and cannabidiol product registration. During the notification, you’re required to submit the following:

  • Product name and category.
  • RP’s name, address, and contact information.
  • Country of origin if made for export. 
  • The first country to land once the product enters the market.
  • Presence of CMR and nanomaterials.
  • Product formulation.
  • The compliant label that contains an external packaging photo.

Do you need the EU cosmetic registration to resell CBD products?

Yes, you do. The CBD cosmetic registration is mandatory for every brand of cosmetic products, whether CBD-related or not. As a reseller, your role is to ensure you source your products from a Cosmetic GMP Certified manufacturer.