If you've been researching which beard products to buy, you've undoubtedly heard the terms CPSR and CPNP thrown around. What are they? Is it important to have them?
Update 2021: Information on CPNP applies only to EU members. For information regarding the new UK Cosmetic Regulations, scroll down to the bottom of this article.
Let's talk about the CPSR first;
CPSR stands for "Cosmetic Product Safety Report", this is a legal requirement for any cosmetic sold within the European Union.
The EU Cosmetics Directive defines a cosmetic as "any substance or preparation intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips and external genital organs) 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 and/or correcting body odours and/or protecting them or keeping them in good condition."
This definition places beard products firmly in the cosmetics category and as such, all beard products much have a CPSR.
So, what is a CPSR?
This is a report prepared by an authorised company, the process takes the formula of a cosmetic and scrutinises the ingredients, allergens and quantities to ensure they comply with EU regulations.
Products that contain certain ingredients such as water must have more in depth testing to ensure any preservatives are working as expected to prevent bacteria growing. This process can take more than 6 weeks to complete.
A report is then generated to prove the safety of the product and facilitate the next step, the CPNP.
What is the CPNP?
The Cosmetics Products Notification Portal (CPNP) is an online notification system for submitting certain technical compliance related information about cosmetic products.
The Regulation states that the designated Responsible Person (or EU Brand Owner) is required to submit certain information about cosmetic products and their product specifications to the CPNP if they intend to make them available on the EU Market.
Who can access the CPNP?
Information submitted to the CPNP is then made available through the portal to the relevant Competent Authorities, enabling market surveillance, analysis and evaluation, as well as to safeguard against grey market or counterfeit products.
The information is also available to Poison Control Centres and other similar bodies established in individual member states for medical treatment and consumer safety purposes.
EU cosmetic product labelling is quite strict, but for good reason. The label is required by law to have certain elements, this is for the consumer's safety.
The label must contain: The name and address of the responsible person (company), the country of origin, the weight or volume, precautions & instructions for use, a list of ingredients (in both INCI and common where possible) and a use by date (in beard products, this is indicated by the "once opened" symbol with months to use once the product has been opened ).
So is it important for a beard product to have a CPSR and be submitted to the CPNP?
Yes, not only is it required by law, it is also completely irresponsible for a brand to market a product without these in place. If you come across a company selling a product without a CPSR then you put yourself at risk if you use the product. This also applies to companies who provide "samples" or "testers" of new products (sometimes with handwritten labels) before they have a CPSR, it is entirely illegal and bad practise.
We've left the EU, what happens to UK Cosmetics?
On 1st January 2021, UK cosmetic entries were removed from the CPNP. Cosmetics sold in the UK must now be notified to the Office for Product Safety and Standards (OPSS) via the new UK notification portal.
In many ways the UK portal is very much like the EU's CPNP. You must have a UK address listed on your labelling.
Can I sell UK cosmetics in the EU still?
Of course, if you want to sell cosmetics in both the UK & EU, you can. The main requirement is that you must be notified to both the UK and EU cosmetic portals. You must also have a responsible person/address based in both locations and your labelling must reflect the UK address for products sold in the UK and the EU address for products sold in the EU. Your PIF documents must be kept at each address in case they are ever requested.
All Balm House products have CPSRs in place as well as being submitted to the UK Cosmetic Notification Portal. Your safety and the quality of our products is extremely important, so we ensure we follow the law to provide you with the best products on the market.