Compliance Checklist

GPSR (General Product Safety Regulation)
Beauty & Cosmetics
France 🇫🇷

Complete GPSR checklist for cosmetic products on Amazon France. Step-by-step with costs, timeline, DGCCRF requirements and common mistakes.

Overview

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has applied since December 13, 2024 to all consumer products in the EU – including all cosmetic and beauty products on Amazon.fr. In France, the DGCCRF (Direction generale de la concurrence, de la consommation et de la repression des fraudes) monitors compliance with product safety regulations particularly strictly. For beauty sellers on Amazon.fr this means: extended documentation requirements, obligation to designate a responsible economic operator in the EU, French-language labeling and compliance with the Code de la consommation.

Does this apply to my product?

The GPSR applies to ALL cosmetic products sold on Amazon.fr – regardless of whether they already fall under the EU Cosmetics Regulation (EC) No 1223/2009. This includes: skincare (soins de la peau), haircare (soins capillaires), makeup (maquillage), perfume (parfums), nail care (soins des ongles), sun protection (protection solaire) and decorative cosmetics. Cosmetic tools such as brushes, sponges and electrical devices (e.g. facial brushes) are also affected. In France, the provisions of the Code de la consommation (Art. L421-1 ff.) and the Loi AGEC for packaging labeling also apply.

Step-by-Step Guide

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Determine your economic operator role

Clarify your role under the GPSR: manufacturer (fabricant), importer (importateur) or distributor (distributeur). In France, the Responsible Person (Personne Responsable) under the Cosmetics Regulation must be established domestically or in the EU.

Estimated time: 1-2 Stunden

Economic operator role documentedRequired

Document in writing whether you are a manufacturer (fabricant), importer (importateur) or distributor (distributeur) under GPSR. For private label products, you are classified as a manufacturer. In France, the DGCCRF is authorized to verify your classification.

Responsible Person (Personne Responsable) in the EU designatedRequired

If your company is based outside the EU, you must designate a Personne Responsable in the EU. For cosmetics under the EU Cosmetics Regulation (Art. 4) this is already mandatory. Under the GPSR, an EU Authorized Representative must additionally be designated as economic operator. In France, this person is the contact point for the DGCCRF.

Power of attorney / appointment letter for EU responsible person (Personne Responsable)

SIRET number of French establishment (if applicable)

If you have an establishment in France or your Personne Responsable is based there, a SIRET number must be available. The DGCCRF uses this to identify the economic operator.

Conduct risk assessment

A risk assessment must be prepared for each beauty product, identifying potential hazards for consumers. For cosmetic products, this overlaps with the safety assessment (CPSR – Cosmetic Product Safety Report) under the EU Cosmetics Regulation. The ANSM (Agence nationale de securite du medicament et des produits de sante) monitors cosmetovigilance in France.

Estimated time: 2-5 Tage

Product-specific risk assessment completedRequired

Document all possible risks: allergic reactions, ingredients on the SVHC list, packaging risks (e.g. swallowing small parts), application risks. In France, particular emphasis is placed on allergen labeling – the DGCCRF regularly conducts targeted inspections of cosmetic products.

Risk assessment document (can be part of the Product Information File)

Cosmetic Product Safety Report (CPSR) availableRequired

The CPSR per Annex I of the EU Cosmetics Regulation by a qualified Safety Assessor is mandatory and serves as a basis for the GPSR risk assessment. The CPSR must reference the Personne Responsable in the EU. The ANSM can request the CPSR as part of cosmetovigilance.

Corrective measures for identified risks definedRequired

Corrective measures must be documented for each identified risk: warnings in French, child safety features, adapted packaging etc. The DGCCRF can request the documentation at any time.

Cosmetovigilance reporting channels to ANSM establishedRequired

In France, adverse effects of cosmetic products must be reported to the ANSM (cosmetovigilance). Set up an internal process to record adverse effect reports from French customers and forward them to the ANSM.

ANSM contact details and reporting forms for cosmetovigilance

Ensure technical documentation

The GPSR requires comprehensive technical documentation demonstrating product safety. For beauty products on Amazon.fr this includes the Product Information File (PIF), CPNP registration and GPSR-specific documents. The documentation must be available upon request from the DGCCRF or ANSM.

Estimated time: 3-7 Tage

Product Information File (PIF) completeRequired

The PIF must contain: product description, safety assessment (CPSR), manufacturing method, evidence for claims, animal testing data (negative declaration). The PIF must be kept at the establishment of the Personne Responsable and be available within 72 hours upon request from the DGCCRF.

Product Information File (PIF) per Art. 11 Cosmetics Regulation

CPNP notification completedRequired

Each cosmetic product must be registered in the EU's Cosmetic Products Notification Portal (CPNP) before being placed on the market. The notification must include the complete formulation. For the French market, the CPNP registration is identical to other EU markets – a separate French registration is not required.

CPNP registration confirmation

Internal traceability processes documentedRequired

You must be able to demonstrate where your products come from and where they were delivered. Document supply chains with batch/lot numbers. In France, the DGCCRF can request the complete supply chain during inspections.

Adapt labeling and packaging

The GPSR tightens product labeling requirements. For beauty products on Amazon.fr, both physical packaging and the Amazon listing must be updated. In France, labeling in French is legally required (Code de la consommation, Art. L112-1). Additionally, the Loi AGEC requirements for packaging labeling (Triman and Info-Tri) apply.

Estimated time: 3-5 Tage

Economic operator contact details on packagingRequired

Name, trade name or brand, postal address and email address of the manufacturer (or the Personne Responsable in the EU) must be on the product or packaging. A website URL alone is NOT sufficient. For the French market, the information must be understandable in French.

Product identification (batch/lot number) on packagingRequired

Each product must be uniquely identifiable, typically through a batch or lot number (numero de lot) on the packaging. This is also mandatory under the EU Cosmetics Regulation.

Warnings and mandatory information in French languageRequired

All safety notices, warnings and instructions for use must be in French on the packaging (Code de la consommation, Art. L112-1). For cosmetics: allergen warnings, usage instructions (mode d'emploi), PAO symbol (period after opening), minimum durability date (date de durabilite minimale) and complete INCI list.

Triman logo and Info-Tri on packaging (Loi AGEC)Required

Since January 1, 2022, all products sold in France must be marked with the Triman logo and Info-Tri (sorting instructions for consumers). This applies to the packaging and potentially the product itself. The Info-Tri must indicate the correct disposal method for each packaging component.

Triman logo and Info-Tri design guidelines from Citeo

Amazon listing updated with GPSR mandatory fieldsRequired

Amazon has introduced new mandatory fields in Seller Central: 'Personne Responsable / Responsible Person', 'Fabricant / Manufacturer', contact details. These must be filled in for each ASIN on Amazon.fr. All listing content must be in French.

Citeo registration and packaging obligations

In France, all companies placing packaged products on the French market must be registered with Citeo (the approved eco-organization for packaging). This replaces the LUCID/dual system registration common in Germany.

Estimated time: 1-3 Tage

Citeo registration completedRequired

Register with Citeo as a packaging producer for the French market. Registration is done online and requires declaration of annual packaging quantities by material (glass, plastic, paper, metal etc.).

Citeo registration confirmation and contract number

Annual packaging declaration submitted to CiteoRequired

Each year, you must submit a declaration to Citeo on the packaging quantities placed on the French market. The declaration covers the weight and type of all packaging materials of your beauty products.

Set up traceability and market surveillance

The GPSR requires ongoing market surveillance and a traceability system. In case of safety issues, you must be able to react immediately. In France, the DGCCRF is the competent market surveillance authority, and the ANSM monitors cosmetovigilance.

Estimated time: 2-3 Tage

Traceability system implementedRequired

Implement a system that allows you to track each batch from production to the end customer. For Amazon FBA: link batch numbers with shipment IDs. The DGCCRF can verify complete traceability.

Complaint management process definedRequired

Set up a process to record, evaluate and, if necessary, report customer complaints about safety issues to authorities. In France, adverse effects must be reported both via Safety Gate/RAPEX (DGCCRF) and to the ANSM (cosmetovigilance).

Reporting channels to DGCCRF and ANSM establishedRequired

In France, the DGCCRF is the central market surveillance authority for product safety. For serious risks, you must inform the DGCCRF via the EU Safety Gate system. For cosmetic-specific adverse effects, the ANSM is the appropriate contact. Reports to the ANSM are submitted via signalement.social-sante.gouv.fr.

Contact details of DGCCRF and ANSM, Safety Gate access

Common Mistakes to Avoid

Only complying with the Cosmetics Regulation and ignoring GPSR

Consequence: Listing suspension on Amazon.fr as GPSR mandatory fields in Seller Central are missing. The DGCCRF can impose fines under the Code de la consommation (up to 15,000 EUR for natural persons, 75,000 EUR for legal entities).

Prevention: GPSR must be observed IN ADDITION to the Cosmetics Regulation. Check all Amazon Seller Central mandatory fields and supplement your documentation with GPSR-specific requirements.

Labeling not in French

Consequence: Violation of the Loi Toubon and the Code de la consommation (Art. L112-1). The DGCCRF can prohibit sales and impose fines. Amazon.fr can block the listing.

Prevention: All mandatory information (warnings, usage instructions, INCI list) must be in French on the packaging. Multilingual labels are permitted, but French must always be included.

Missing Citeo registration and no Triman/Info-Tri on packaging

Consequence: Violation of the Loi AGEC. Fines up to 100,000 EUR possible. The DGCCRF is increasingly conducting inspections regarding Triman and Info-Tri obligations.

Prevention: Register with Citeo early and adapt your packaging with the Triman logo and correct Info-Tri. Use the free Citeo tools for design.

No EU responsible person (Personne Responsable) designated

Consequence: Products may not be placed on the EU market. Amazon is increasingly blocking listings without a designated EU responsible person. The DGCCRF can immediately prohibit sales.

Prevention: Appoint an EU Authorized Representative (e.g. SPACEGOATS as EC-REP) or establish an EU subsidiary. The Personne Responsable must be designated for both the Cosmetics Regulation and the GPSR.

INCI list not in correct order or incomplete

Consequence: Violation of both Cosmetics Regulation AND GPSR simultaneously. Recall, fine, Amazon listing suspension. The DGCCRF checks INCI lists during focused inspection campaigns.

Prevention: List INCI names in descending order of concentration. For fragrances, list the 26 notifiable allergens individually. The INCI list must be identical on the packaging and in the Amazon listing.

Frequently Asked Questions

Q1Does the GPSR also apply to cosmetic products already covered by the Cosmetics Regulation?

Yes. The GPSR applies in addition to the EU Cosmetics Regulation. While the Cosmetics Regulation governs specific safety requirements for ingredients, the GPSR covers general product safety aspects such as traceability, market surveillance and notification obligations. In France, the DGCCRF monitors compliance with both regulatory frameworks.

Q2Must all information on the packaging be in French?

Yes. The French language law (Loi Toubon, 1994) and the Code de la consommation (Art. L112-1) require all consumer information to be in French. Multilingual labels are permitted, but French must always be included. INCI names themselves are internationally standardized and do not need to be translated.

Q3What is the difference between LUCID (Germany) and Citeo (France)?

In Germany, you must register with LUCID (Central Packaging Register) and contract a system operator (e.g. Gruener Punkt). In France, Citeo replaces this system as the sole approved eco-organization for household packaging. Registration is done directly with Citeo – there is no separate registry like LUCID in France. Citeo contributions cover collection and recycling.

Q4Do I need an EU responsible person if I sell from the USA or China on Amazon.fr?

Yes, mandatory. The GPSR requires all non-EU sellers to have a Personne Responsable based in the EU. For cosmetics, this is already mandatory under the EU Cosmetics Regulation (Art. 4). This person is the contact point for the DGCCRF and ANSM and shares responsibility for product safety. SPACEGOATS offers this service as EC-REP.

Q5How much does GPSR compliance cost for a single beauty product on Amazon.fr?

For a single cosmetic product, expect 700-3,000 EUR: safety assessment/CPSR (500-2,000 EUR), CPNP registration (free if done yourself), packaging adaptation including French labeling, Triman and Info-Tri (200-800 EUR), Citeo contributions (80-500 EUR/year). For multiple products, unit costs decrease significantly.

Q6What is the role of the ANSM for cosmetic products?

The ANSM (Agence nationale de securite du medicament et des produits de sante) is responsible for cosmetovigilance in France. It collects and evaluates adverse effects of cosmetic products. Sellers and the Personne Responsable must report serious adverse effects to the ANSM without delay. The ANSM can also order product recalls.

GPSR (General Product Safety Regulation)Beauty & CosmeticsFrance 🇫🇷