GPSR (General Product Safety Regulation)
Personal Care
Germany 🇩🇪

Determine product category under Cosmetics RegulationRequired

Assign your product to one of the categories in Annex I of the EU Cosmetics Regulation (e.g., skin care, oral care, sun protection). Verify whether your product qualifies as a cosmetic product or falls under pharmaceutical/medical device regulations. For sunscreen products, EU Recommendation 2006/647/EC must be considered.

Check prohibited and restricted ingredientsRequired

Cross-reference all ingredients against Annexes II (prohibited), III (restricted), IV (colorants), V (preservatives), and VI (UV filters) of the EU Cosmetics Regulation. Consider recent amendments and Commission decisions. Additional notification and labelling obligations apply to nanomaterials.

Identify additional applicable regulationsRequired

Check whether additional regulations apply to your product or its packaging: VerpackG (Packaging Act) with LUCID registration, CLP Regulation for labelling of hazardous ingredients, Aerosol Directive 75/324/EEC for spray cans (deodorants, shaving foam). For sunscreen products, consider EU Commission recommendations on efficacy and labelling.

Designate EU Responsible PersonRequired

The Responsible Person must be established in the EU and is responsible for product safety, compliance with the Cosmetics Regulation, and maintaining the Product Information File (PIF). For EU-based manufacturers, the manufacturer automatically serves as the Responsible Person. For importers from third countries, an external service provider or EU subsidiary can be designated. Under GPSR, the Responsible Person must additionally be indicated on the product or packaging.

Complete CPNP notificationRequired

All cosmetic products must be notified via the EU Commission's CPNP (Cosmetic Products Notification Portal) before being placed on the market. The notification includes: product category, product name, Responsible Person name and address, country of origin, EU member state of first marketing, emergency contact details, presence of nanomaterials, CMR substances or substances under Article 14, frame formulation, and where applicable, original label/photo. Extended notification requirements apply to sunscreen products and products containing nanomaterials.

Prepare Product Information File (PIF)Required

The PIF must be compiled according to Article 11 of the Cosmetics Regulation and maintained by the EU Responsible Person. It includes: product description, Cosmetic Product Safety Report (CPSR) per Annex I, manufacturing method and GMP declaration (ISO 22716), proof of efficacy for product claims, and animal testing data. The PIF must be available for 10 years after the last batch is placed on the market.

Mandatory labelling per Cosmetics RegulationRequired

The following information must appear on the packaging or container: name and address of the Responsible Person, nominal content (weight or volume), best before date (if shelf life under 30 months) or PAO symbol (jar symbol with month indication), batch number (batch code), function of the product (unless obvious), INCI ingredient list in descending order, warnings per Annex III of the Cosmetics Regulation. All consumer-facing information must appear in German.

Implement GPSR-specific labellingRequired

In addition to cosmetics labelling, GPSR (Article 9) requires: name, registered trade name or registered trademark of the manufacturer, postal address and electronic address of the manufacturer, for imported products additionally name and contact details of the importer, product type and identification (e.g., article number, EAN/GTIN) for unique identification, warnings and safety information in German. All information must be legible, comprehensible, and easily accessible.

Validate product claimsRequired

All advertising claims must comply with EU Regulation (EU) 655/2013 on common criteria for cosmetic claims. Prohibited are: therapeutic efficacy claims, exaggerated promises, misleading before-after images. For sunscreen products, SPF claims must conform to the Colipa standard (ISO 24444). For deodorants, correct distinction must be made between 'deodorant' and 'antiperspirant'.

LUCID registration with ZSVRRequired

Every first distributor of packaging in Germany must register in the LUCID packaging register of the Central Agency Packaging Register (ZSVR) before placing products on the market. Registration is free and done at verpackungsregister.org. You need: company name, address, tax number/VAT ID, and details on packaging materials and quantities.

Conclude system participation agreementRequired

Conclude an agreement with a dual system (e.g., Der Gruene Punkt, Interseroh, Reclay, BellandVision) for the take-back and recycling of your packaging. Quantities must match those reported in LUCID. Data reporting is required annually (and potentially during the year).

Enter GPSR attributes in Seller CentralRequired

Since December 2024, Amazon.de requires the following mandatory GPSR fields: manufacturer name and address, EU Responsible Person name and address (if different), contact email or URL for the responsible economic operator, warnings and safety information in German. These fields can be found in Seller Central under 'Compliance information' in the product editor. Missing information may result in listing deactivation.

Product images and A+ Content with compliance informationRequired

Ensure product images clearly show labels with all mandatory information (INCI list, PAO, batch number, Responsible Person). A+ Content should include safety instructions and usage instructions in German. Avoid health claims or medical claims in images and text.

Enter LUCID number and EPR proof in AmazonRequired

Enter your LUCID registration number in Amazon Seller Central under EPR settings (Extended Producer Responsibility). Amazon automatically verifies this number against the LUCID register. Failure to provide or incorrect numbers may result in loss of selling privileges on the German marketplace.

Establish internal monitoring systemRequired

Under GPSR Article 9, manufacturers and importers must operate an appropriate complaints system and maintain an internal register of complaints, non-compliant products, and recalls. For cosmetic products, additional reporting obligations for serious undesirable effects under Article 23 of the Cosmetics Regulation apply. Establish processes for: customer complaints via Amazon and direct channels, monitoring product reviews for safety signals, reporting serious undesirable effects to the competent authority (BVL) and via the SUE reporting system, annual review of the PIF and safety report.

Ensure documentation and traceabilityRequired

Maintain complete traceability via batch codes from manufacturer to end consumer. GPSR requires economic operators to document their supply chain for 10 years. Retain all compliance documents (PIF, CPSR, CPNP confirmation, test reports, LUCID proof, GMP certificates) for at least 10 years after the last batch is placed on the market.