EU Cosmetics Seller Compliance Index 2026

EU cosmetics seller compliance now touches 1,109 active sellers that Eldris tracked across Amazon's four largest EU marketplaces. Germany accounts for 435, Spain 310, Italy 226 and France 138. Of them, 140 are based outside the EU and cannot legally sell until they appoint an EU Responsible Person.

Every one of these sellers falls under Regulation (EC) 1223/2009. The obligation begins before the first sale, not after it.

This index summarises what the data shows about the obligations cosmetics sellers face today. It links to deeper reports for each market, origin country and product type. Each linked report drills into one slice of the same 1,109-seller dataset.

What EU cosmetics seller compliance actually requires

Three obligations sit at the centre of Regulation (EC) 1223/2009. Each applies before a product is placed on the EU market, not after the first sale.

First comes a Responsible Person under Article 4. This must be a person or company established inside the EU. The Responsible Person holds the product file and answers to authorities.

Second comes a notification through the Cosmetic Products Notification Portal (CPNP) under Article 13. The notification records the product, its formula frame and the Responsible Person. It must exist before any unit ships.

Third comes a Cosmetic Product Safety Report (CPSR) under Article 10 and Annex I. The CPSR is a two-part dossier. Part A gathers the safety data, and Part B records the assessor's conclusion.

Missing any one of the three makes the product non-compliant. A marketplace listing does not change that. The seller, brand owner or importer carries the legal duty.

The EU-4 marketplace picture

Cosmetics sellers concentrate in the four large Western European markets. The split below comes directly from the tracked dataset. It reflects where sellers list, not necessarily where they are based.

Germany — 435 sellers

Germany is the single largest market in the data with 435 cosmetics sellers. German enforcement is active, and market-surveillance authorities check both notification and labelling.

CPNP plus Responsible Person duties apply to every product. See the Amazon Germany cosmetics report for the full breakdown.

Spain — 310 sellers

Spain follows with 310 sellers. The obligations mirror the rest of the EU because the Regulation applies uniformly. A notification filed once is valid across all member states.

The Amazon Spain cosmetics report covers the detail.

Italy and France — 226 and 138 sellers

Italy hosts 226 cosmetics sellers and France 138. Both require CPNP notification and a Responsible Person.

Read the Amazon Italy report for market specifics.

Where the 140 non-EU brands come from

Of the 1,109 sellers, 140 are established outside the EU. Each must appoint an EU Responsible Person before notification.

The duty does not depend on sales volume or product count. A single SKU triggers it just as a full range does.

The largest non-EU groups are the United Kingdom with 49 sellers and China with 31. China-based brands carry the same Article 4 obligation as any other third country. Our China cosmetics sellers report sets out the path from manufacture to notification.

The UK became a third country after Brexit, which split the notification system. UK brands now face an EU CPNP and a separate UK SCPN.

A product compliant in London is not automatically compliant in Berlin. Our UK cosmetics sellers report explains the divide.

The wider non-EU group spans many origin countries, and the obligation is identical across all of them. The non-EU Responsible Person report covers who needs an RP and why.

Product types and the obligations they trigger

The product mix shapes the workload. Skincare dominates the leaderboard, and the safety-report burden rises with the number of distinct formulations a seller lists.

Skincare leads with 641 sellers, then personal care 374, haircare 256, makeup 115 and fragrance 107. Every category needs CPNP notification, a Responsible Person and a CPSR. Some categories add extra duties on top.

Skincare sellers face a CPSR for each formulation, which is the heaviest documentation load in the dataset. See the skincare CPSR report for the detail.

Haircare products are full cosmetics with labelling duties under Article 19. Shampoos and conditioners are not exempt because they rinse off. The haircare compliance report covers the 256 sellers in this group.

Fragrance adds allergen labelling under Annex III. Listed allergens above set thresholds must appear on the label. The fragrance compliance report covers the 107 perfume sellers.

How ingredient and safety rules fit together

Ingredients are checked against the EU's published lists. The CosIng database records permitted, restricted and prohibited substances. Every formulation must be screened against it before the safety assessment begins.

The CPSR ties that screening to a documented safety assessment. A qualified safety assessor signs Part B of Annex I. Without that signature, the product cannot be notified or sold.

The Responsible Person keeps the Product Information File (PIF) ready for ten years after the last batch. Authorities can request it at any time. The PIF holds the CPSR, the label, the method of manufacture and the proof of effect claims.

Eldris handles all three core duties end to end. Our CPNP and CPSR service covers the Responsible Person role, the safety report and the portal submission as one fixed-price package.

Data source: Eldris proprietary tracking of 16,931 active Amazon third-party sellers across 22 marketplaces, observed October 2025–February 2026. Figures are aggregated and anonymised; no individual seller is identifiable. Cosmetics sellers identified via product-category keyword classification.

Frequently Asked Questions

How many cosmetics sellers operate on Amazon's EU marketplaces?

Eldris tracked 1,109 cosmetics sellers across Amazon's four largest EU marketplaces: Germany 435, Spain 310, Italy 226 and France 138. Each is subject to the EU Cosmetics Regulation.

How many cosmetics sellers need an EU Responsible Person?

Of the 1,109 sellers tracked, 140 are based outside the EU. Each must appoint an EU-established Responsible Person under Article 4 before its products can be placed on the market.

What is the most common cosmetics sub-type sold by EU sellers?

Skincare leads with 641 sellers, followed by personal care 374, haircare 256, makeup 115 and fragrance 107. Every category falls under Regulation (EC) 1223/2009.

What are the three core EU cosmetics obligations?

An EU Responsible Person under Article 4, a CPNP notification before sale under Article 13, and a Cosmetic Product Safety Report under Article 10. All three apply per product.

Does selling on Amazon make me compliant automatically?

No. Amazon is a marketplace, not a Responsible Person. The seller or brand owner remains liable for CPNP notification, the CPSR and a Responsible Person under Regulation (EC) 1223/2009.