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How Long a CPSR Takes and What Restarts the Clock

Eldris delivers your CPSR and PIF 5–10 working days after receiving your complete documents. If the safety assessor needs more from you, the question appears in your portal, and the 5–10 working days start again from the day you answer. It is a restart, never a pause.

You pay first, then upload your documents in your Eldris portal. Article 10 of Regulation (EC) No 1223/2009 requires the safety assessment before a cosmetic is placed on the EU market, so the order has to come before that point.

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When does the count of working days begin?

The count begins when Eldris has your complete documents.

It does not begin when you pay or when the first file is uploaded. You pay first, then upload in your Eldris portal. Upload what you have, and Eldris tells you what is still missing. Complete therefore means that nothing on that list remains. The documents include the formula, safety data sheets and answers on water, alcohol or solvents, fragrance and the packaging material. A fragrance product also needs the IFRA certificate, the allergen declaration and the fragrance level. Stability data, a challenge test and a GMP statement help but are not needed to start, so the order can begin before a laboratory result arrives. Eldris names anything else that is missing, and the day the list is empty is the day the 5–10 working days begin. Uploading what you have at once is the quickest way to reach that day.

Can a CPSR arrive the same day?

Eldris does not commit to same-day delivery.

The commitment is 5–10 working days after complete documents, and a safety assessor writes the CPSR and signs it. Before the assessment starts, Eldris checks the formula against Annexes II–VI for banned and restricted substances. The assessor then writes Part A, the safety information, and Part B, the safety assessment. Annex I of the Regulation sets out these two parts for a CPSR. A qualified safety assessor signs both parts. The PIF is prepared with the report, and the test reports you supply go into it. The 5–10 working days is the commitment for the CPSR and PIF together, counted from complete documents. The notification and any laboratory test sit outside it. Eldris is not a testing laboratory, so no laboratory work sits inside the count. Both documents arrive in your Eldris portal, which is also where you upload.

What restarts the clock, and why is it never a pause?

The clock restarts when the safety assessor needs more from you and you answer.

The question appears in your portal, and the 5–10 working days start again from the day you answer. It is a restart, not a pause. The difference matters in practice. A pause would keep the days already counted and add the rest later. A restart begins the full 5–10 working days again. The days counted before the question are not counted, however far the assessment had got. The new period also begins on the day you answer, not on the day the question appeared, so the time between the question and your answer is not counted either. Answering in the portal is what starts the new period, which makes the speed of your answer part of the schedule that sits with you. The same rule applies to every question the assessor raises, not only the first.

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What happens after the CPSR and PIF arrive?

After the CPSR and PIF arrive in your Eldris portal, the Responsible Person files the notification, which Article 13 requires before the product is placed on the market.

The 5–10 working days covers the CPSR and PIF only, not the notification. In the EU, the notification goes through the Commission's CPNP, its free online notification system. Eldris files it when it is your EU Responsible Person and you have ordered the filing. Otherwise your own Responsible Person files it. Either way, the filing is its own step and is not folded into the CPSR delivery. Great Britain has its own rule. Under Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, the Responsible Person notifies electronically before placing the product on the market. The CPSR and the notification are both needed before the product is placed on the market, so plan the order, the upload and any answers to the assessor around that date.

Where do the assessor's questions appear?

Questions from the safety assessor appear in your Eldris portal.

It is the place where you upload documents and where the CPSR and PIF arrive. Answering there is what starts the new 5–10 working days. The portal is therefore the one place to watch, from the first upload to the finished files. Upload what you have at the start and answer any question as soon as it appears, because each answered question starts a new period. The per-formula fee is shown on the pricing page, and the fee does not change with the number of ingredients. The cosmetics fees are paid once, so a longer wait adds no monthly charge. The post on CPSR cost sets out what a safety report costs and carries the same 5–10 working days line. The cosmetics compliance service page gives the overview of what Eldris prepares, and the FAQ entry on timing holds the short answer.

Frequently asked questions

Does payment start the 5–10 working days?

No. The count starts when your documents are complete. You pay first, then upload in your Eldris portal, and Eldris tells you what is still missing. Payment alone does not start the count, and an incomplete upload does not either. The first day of the count is the day nothing is missing.

What if I answer the assessor's question late?

The 5–10 working days start again from the day you answer. The time between the question and your answer is not counted as part of the new period, and the days counted earlier do not carry over. A late answer therefore moves the delivery date by the same amount, and a quick answer starts the new period sooner.

Is the notification included in the 5–10 working days?

No. The 5–10 working days is the commitment for the CPSR and PIF. The Responsible Person files the notification as a separate step, and Eldris does so when it is your EU Responsible Person and the filing is ordered. Great Britain has its own notification, priced separately.

Where do I receive the CPSR and PIF?

Your CPSR and PIF arrive in your Eldris portal. The same portal is where you upload documents and where any question from the safety assessor appears, so one place shows the whole order. Part A and Part B of the CPSR are signed by a qualified safety assessor.

Can I get the CPSR today if my documents are ready?

Eldris does not commit to that. The commitment is 5–10 working days after complete documents, and a safety assessor writes and signs the report. The count runs in working days from the point where nothing is missing, so documents that arrive early start it only when they are complete. The finished files then appear in your portal.

Do fragrance products need extra documents before the count starts?

Yes. A fragrance product also needs the IFRA certificate, the allergen declaration and the fragrance level. Eldris tells you if any item is still missing, and the count begins once nothing is. Stability data and a GMP statement help but are not needed to start.

Can I order before my stability or challenge test is done?

Yes. Stability data and a challenge test help but are not needed to start. Eldris asks for a challenge test report (ISO 11930) for products that contain water, not water-free ones, but you can start your order without it. The test reports you supply go into the PIF.

Sources

  1. Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
  2. Cosmetic Products Notification Portal (CPNP), European Commission
  3. Commission Regulation (EU) 2023/1545 on the labelling of fragrance allergens (EUR-Lex)
  4. 34, legislation.gov.uk

From the Eldris channel

60-second answers

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Written by

Eldris Cosmetics

The Eldris Compliance Team prepares CPSR safety reports and PIF files for cosmetics brands selling in the EU, and writes these guides on Regulation (EC) No 1223/2009.

Cosmetics compliance by Eldris

CPSR and PIF from £195 per formula, 5–10 working days

Eldris prepares the Cosmetic Product Safety Report (CPSR) and the Product Information File (PIF) for each formula. A variation of an assessed formula (new shade or scent) is £39.95. When Eldris is your EU Responsible Person, Eldris also files the CPNP notification for £99 per CPSR.

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The legal representative that sellers based outside the EU must name on their products before selling there, under Regulation (EC) No 1223/2009 for cosmetics (and the General Product Safety Regulation, GPSR, for other products). The UK has its own product rules; Eldris covers the UK as an additional market. Certificate and label address issued in under 60 minutes.

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