Compliance Checklist
Complete GPSR checklist for cosmetic products on Amazon Germany. Step-by-step with costs, timeline 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.de. For beauty sellers this means: extended documentation requirements, obligation to designate a responsible economic operator in the EU, and new traceability requirements.
Does this apply to my product?
The GPSR applies to ALL cosmetic products sold on Amazon.de – regardless of whether they already fall under the EU Cosmetics Regulation (EC) No 1223/2009. This includes: skincare, haircare, makeup, perfume, nail care, sun protection and decorative cosmetics. Cosmetic tools such as brushes, sponges and electrical devices (e.g. facial brushes) are also affected.
Step-by-Step Guide
Clarify your role under the GPSR: manufacturer (if you produce or sell under your own brand), importer (if you bring products from outside the EU) or distributor (if you resell existing branded products).
Estimated time: 1-2 Stunden
Economic operator role documentedRequired
Document in writing whether you are a manufacturer, importer or distributor under GPSR. For private label products, you are typically classified as a manufacturer.
Responsible person in the EU designated (if based outside EU)Required
If your company is based outside the EU, you must designate a responsible person (Authorized Representative) in the EU. This person must be established in the EU.
A risk assessment must be prepared for each beauty product, identifying potential hazards for consumers. For cosmetic products, this partially overlaps with the safety assessment under the Cosmetics Regulation.
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.
Safety assessment under Cosmetics Regulation availableRequired
The safety assessment according to Annex I of the EU Cosmetics Regulation by a qualified Safety Assessor is mandatory and can serve as a basis for the GPSR risk assessment.
Corrective measures for identified risks definedRequired
Corrective measures must be documented for each identified risk: warnings, child safety features, adapted packaging etc.
The GPSR requires comprehensive technical documentation demonstrating product safety. For beauty products this includes the Product Information File (PIF), CPNP registration and GPSR-specific documents.
Estimated time: 3-7 Tage
Product Information File (PIF) completeRequired
The PIF must contain: product description, safety assessment, manufacturing method, evidence for claims, animal testing data (negative declaration).
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.
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.
The GPSR tightens product labeling requirements. For beauty products on Amazon.de, both physical packaging and the Amazon listing must be updated.
Estimated time: 2-4 Tage
Economic operator contact details on packagingRequired
Name, trade name or brand, postal address and email address of the manufacturer (or EU responsible person) must be on the product or packaging. A website URL alone is NOT sufficient.
Product identification (batch/lot number) on packagingRequired
Each product must be uniquely identifiable, typically through a batch or lot number on the packaging.
Warnings in German languageRequired
All safety notices and warnings must be in German on the packaging. For cosmetics: allergen warnings, usage instructions, PAO symbol (Period After Opening).
Amazon listing updated with GPSR mandatory fieldsRequired
Amazon has introduced new mandatory fields in Seller Central: 'Responsible Person', 'Manufacturer', contact details. These must be filled in for each ASIN.
The GPSR requires ongoing market surveillance and a traceability system. In case of safety issues, you must be able to react immediately.
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.
Complaint management process definedRequired
Set up a process to record, evaluate and, if necessary, report customer complaints about safety issues to authorities (RAPEX/Safety Gate).
Reporting channels to BAuA / market authorities knownRequired
In Germany, the Federal Institute for Occupational Safety and Health (BAuA) is the central reporting point. For serious risks, you must inform the competent authority via the Safety Gate system.
Common Mistakes to Avoid
Only complying with the Cosmetics Regulation and ignoring GPSR
Consequence: Listing suspension on Amazon as GPSR mandatory fields in Seller Central are missing. In the worst case, fines from market surveillance authorities.
Prevention: GPSR must be observed IN ADDITION to the Cosmetics Regulation. Check all Amazon Seller Central mandatory fields and supplement your documentation.
Missing or incomplete contact details on packaging
Consequence: Amazon can deactivate the listing. The GPSR explicitly requires name, postal address and electronic contact details (email) on the product.
Prevention: Ensure that name, company address and email address are on the packaging – not just a website URL.
No EU responsible person designated (for non-EU based companies)
Consequence: Products may not be placed on the EU market. Amazon is increasingly blocking listings without a designated EU responsible person.
Prevention: Appoint an EU Authorized Representative (e.g. SPACEGOATS as EC-REP) or establish an EU subsidiary.
INCI list not in correct order or incomplete
Consequence: Violation of both Cosmetics Regulation AND GPSR simultaneously. Recall, fine, Amazon listing suspension.
Prevention: List INCI names in descending order of concentration. For fragrances, list the 26 notifiable allergens individually.
Frequently Asked Questions
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.
Amazon can deactivate the listing or block the ASIN entirely. Since December 2024, Amazon actively checks the 'Responsible Person' and 'Manufacturer Information' fields in Seller Central. Without this information, listings are increasingly being blocked.
Yes, mandatory. The GPSR requires all non-EU sellers to have a responsible person based in the EU. This person is the contact point for authorities and shares responsibility for product safety. SPACEGOATS offers this service as EC-REP.
The GPSR requirements are identical. However, natural cosmetics often have higher risks for allergens (essential oils) and require particularly careful treatment in the risk assessment. The INCI list must separately list natural allergens such as linalool, limonene etc.
For a single cosmetic product, expect 500-2,500 EUR: safety assessment (500-2,000 EUR), CPNP registration (free if done yourself), packaging adaptation (100-500 EUR). For multiple products, unit costs decrease significantly as many processes are reusable.