Compliance Checklist

GPSR (General Product Safety Regulation)
Personal Care
Italy 🇮🇹

Complete GPSR compliance checklist for personal care products on the Italian market. Cosmetics Regulation, Italian labeling, CONAI packaging obligations and Amazon.it mandatory fields.

Overview

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has been mandatory for all consumer products in the EU since December 13, 2024 - including all personal care products on Amazon.it. This covers classic cosmetic articles (shower gel, deodorant, oral care, shaving products) as well as personal care accessories such as razors, epilators, wet wipes, and electric toothbrushes. Many of these products additionally fall under the EU Cosmetics Regulation (EC) No 1223/2009, meaning both frameworks must be satisfied in parallel. In Italy, the Ministero della Salute (Ministry of Health) is responsible for cosmetics regulatory oversight, while the Istituto Superiore di Sanita (ISS) conducts scientific safety assessments and risk evaluations. General product safety under the GPSR falls under the Ministero delle Imprese e del Made in Italy (MIMIT) together with the Camere di Commercio. For personal care sellers on Amazon.it this means: designating an EU Responsible Person, Italian-language labeling per the Codice del Consumo (D.Lgs. 206/2005), CPNP registration for cosmetic products, and CONAI packaging obligations for all packaging materials.

Does this apply to my product?

This checklist applies to all economic operators placing personal care products on Amazon.it. This includes: shower and bath products (bagnoschiuma, gel doccia), deodorants (deodoranti), oral care products (dentifrici, spazzolini), shaving articles (rasoi, schiuma da barba), epilators and trimmers, wet wipes (salviette umidificate), intimate hygiene products, and body lotions. Products with a cosmetic purpose (cleansing, care, fragrance, protection of skin/mucous membranes) are additionally subject to the EU Cosmetics Regulation. Electrical devices such as razors and electric toothbrushes must also comply with the Low Voltage Directive and EMC Directive. In Italy, all information must be in Italian (Codice del Consumo, D.Lgs. 206/2005), and CONAI packaging obligations apply to all packaging materials.

Step-by-Step Guide

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Determine Economic Operator Role and Designate EU Responsible Person

Clarify your role under the GPSR (manufacturer, importer, distributor) and designate an EU Responsible Person. For cosmetic personal care products, this obligation overlaps with the 'Persona responsabile' role under the EU Cosmetics Regulation.

Estimated time: 1-5 Tage

Document economic operator roleRequired

Document in writing whether you are a manufacturer (fabbricante), importer (importatore), or distributor (distributore). Private label sellers of personal care products are typically considered manufacturers under both regulations.

Designate EU Responsible Person for the Italian marketRequired

Designate a person established in the EU as Responsible Person (Responsabile). For the Italian market, it is advantageous if the responsible person can communicate in Italian, as the Ministero della Salute and the Camere di Commercio frequently correspond in Italian. The responsible person must be able to present technical documentation within 10 days upon request.

Power of attorney or mandate agreement with the EU Responsible PersonProof of EU establishment (Visura camerale / commercial register extract)

Prepare Safety Assessment and Technical Documentation

For cosmetic personal care products on the Italian market, the EU Cosmetics Regulation (EC) No 1223/2009 and GPSR apply in parallel. Electrical devices (razors, toothbrushes, epilators) additionally require Low Voltage and EMC compliance. Technical documentation must include risk analysis, Product Information File (PIF), CPNP registration, and GPSR-specific evidence.

Estimated time: 1-4 Wochen

Prepare safety assessment per Cosmetics Regulation and GPSR risk analysisRequired

The safety assessment per Annex I of the EU Cosmetics Regulation by a qualified Safety Assessor is mandatory for cosmetic personal care products and can serve as the basis for the GPSR risk analysis. The ISS (Istituto Superiore di Sanita) regularly publishes scientific evaluations of cosmetic ingredients that should be considered in the risk analysis. Additionally, a GPSR-specific risk analysis must cover general product safety aspects (packaging, application risks, mechanical hazards from razor blades).

Safety assessment by Safety Assessor (Valutazione della sicurezza)GPSR risk analysis document

Complete Product Information File (PIF) and CPNP registrationRequired

The PIF must contain product description, safety assessment, manufacturing method, evidence for claims, and animal testing negative declaration. Each cosmetic personal care product must be registered in the CPNP before market placement. Purely mechanical products without a cosmetic purpose (e.g., plain razor blades without a lubricating strip) do not require CPNP registration, but do require a GPSR risk analysis.

Product Information File (PIF) per Art. 11 Cosmetics RegulationCPNP registration confirmation

Verify compliance of electrical devices (if applicable)

Electrical personal care devices such as razors, epilators, and electric toothbrushes additionally require compliance with the Low Voltage Directive (2014/35/EU), the EMC Directive (2014/30/EU), and, if applicable, the Radio Equipment Directive (for Bluetooth functionality). A CE Declaration of Conformity and test reports from an accredited laboratory are required.

CE Declaration of Conformity for electrical devicesTest report from an accredited laboratory (Low Voltage/EMC)

Prepare traceability documentationRequired

Document the complete supply chain with batch/lot numbers (numero di lotto). Each product unit must be traceable from production to end customer. For Amazon FBA, batch numbers must be linked with shipment IDs.

Italian-Language Labeling and CONAI Packaging Obligations

In Italy, all product information must be in Italian (Codice del Consumo, D.Lgs. 206/2005). Additionally, Italian packaging legislation requires registration with CONAI and the application of disposal instructions per D.Lgs. 116/2020.

Estimated time: 1-3 Wochen

Create complete product labeling in ItalianRequired

For cosmetic personal care products on Amazon.it, the following must be in Italian: product name, INCI list, batch/lot number, best-before date (da usarsi preferibilmente entro) or PAO symbol, usage instructions (modalita d'uso), warnings (avvertenze), and allergen warnings. For electrical devices (razors, toothbrushes), an Italian-language instruction manual and safety notices must also be included.

Packaging layout with complete Italian labeling

CONAI registration and packaging labeling per D.Lgs. 116/2020Required

Register with CONAI (Consorzio Nazionale Imballaggi) as a packaging first-importer in Italy. Since January 1, 2023, all packaging in Italy must be labeled with material codes and disposal instructions (e.g., 'Raccolta differenziata - Verificare le disposizioni del proprio comune'). CONAI contributions (Contributo Ambientale CONAI - CAC) vary by packaging material - especially relevant for plastic packaging of shower gel and deodorant as well as blister packs for razor blades.

CONAI registration confirmationPackaging layout with material codes and disposal instructions

EU Responsible Person contact details on packaging and listingRequired

Name, postal address, and email of the EU Responsible Person must appear on the packaging or an accompanying document. Additionally, the data must be entered in the GPSR mandatory fields of the Amazon.it listing. A website URL alone is not sufficient.

Amazon.it GPSR Compliance Fields and Market Surveillance

Complete Amazon GPSR mandatory fields and establish market surveillance for the Italian market. Complaints in Italy can be filed via MIMIT, the Ministero della Salute, or local Camere di Commercio.

Estimated time: 2-5 Tage

Complete GPSR mandatory fields in Amazon Seller Central for Amazon.itRequired

Enter the complete EU Responsible Person data, manufacturer information, and safety warnings in the Amazon GPSR fields. Ensure all data matches the physical packaging. For electrical devices, CE marking and conformity documents must also be deposited.

Set up complaint management and reporting channels to Italian authoritiesRequired

Set up a complaint register and define reporting channels to MIMIT, the Ministero della Salute, and the EU Safety Gate. In Italy, consumers can also file complaints about cosmetic-related safety issues via the local ASL (Aziende Sanitarie Locali). Regularly monitor RAPEX/Safety Gate notifications for personal care products.

Internal procedure document for complaints and recalls

Common Mistakes to Avoid

CONAI registration and packaging labeling ignored

Consequence: Fines up to EUR 40,000 per D.Lgs. 152/2006. The Guardia di Finanza increasingly inspects CONAI obligations for online sales of personal care products, especially for plastic packaging of shower gel, deodorant, and razor blade blister packs.

Prevention: Register with CONAI in time and apply material codes and disposal instructions on all packaging. SpaceGoats can handle CONAI registration for you.

Product labeling not in Italian or incomplete INCI list

Consequence: Violation of the Codice del Consumo (D.Lgs. 206/2005) and the EU Cosmetics Regulation. The Ministero della Salute can impose sales bans and the Camere di Commercio can issue fines from EUR 1,000 to EUR 100,000. Amazon.it suspends listings with missing Italian labeling.

Prevention: Ensure all mandatory information is in Italian. Have the INCI list reviewed by a specialist and observe allergen labeling requirements for fragranced products.

Electrical personal care devices sold without CE conformity evidence

Consequence: Razors, epilators, and electric toothbrushes without valid Low Voltage and EMC test reports violate both the GPSR and the respective EU directives. Market surveillance authorities can order sales bans and recalls, and Amazon.it can suspend listings.

Prevention: Have electrical personal care devices tested by an accredited laboratory before listing and keep the CE Declaration of Conformity and technical documentation on hand.

No EU Responsible Person designated or Italian authority inquiries not answered

Consequence: MIMIT and the Ministero della Salute can impose a market placement ban. Amazon.it suspends listings without a designated EU Responsible Person. The Camere di Commercio can impose additional sanctions.

Prevention: Designate an EU Responsible Person who can communicate with Italian authorities. SpaceGoats assumes this function including authority communication.

Frequently Asked Questions

Q1Do I need to register with CONAI if I sell personal care products to Italy via Amazon FBA?

Yes. Every economic operator placing packaged products on the Italian market for the first time must register with CONAI and pay the Contributo Ambientale CONAI (CAC). This also applies to Amazon FBA sellers of shower gel, deodorant, razor blades, and similar products. Packaging must also be labeled with material codes and disposal instructions per D.Lgs. 116/2020.

Q2Which authority is responsible for personal care market surveillance in Italy?

In Italy, several authorities are responsible: the Ministero della Salute (Ministry of Health) oversees cosmetics regulatory aspects, the Istituto Superiore di Sanita (ISS) conducts scientific safety assessments, MIMIT is responsible for general product safety (GPSR), and the Camere di Commercio conduct local inspections. For electrical personal care devices, the market surveillance authorities responsible for electrical products additionally check CE conformity.

Q3Does the GPSR also apply to personal care products already covered by the Cosmetics Regulation?

Yes. The GPSR applies in addition to the EU Cosmetics Regulation (EC) No 1223/2009. While the Cosmetics Regulation governs specific safety requirements for ingredients, the GPSR covers general product safety aspects: traceability, market surveillance, EU Responsible Person, and notification duties for safety incidents. For purely mechanical or electrical personal care products without a cosmetic purpose (e.g., certain razor accessory parts), only the GPSR applies.

Q4How much does GPSR compliance cost for a single personal care product on Amazon.it?

For a single cosmetic personal care product, expect EUR 700-2,500: safety assessment (EUR 500-2,000), CPNP registration (free if done yourself), packaging adaptation with Italian labeling and CONAI markings (EUR 100-500), EU Responsible Person (EUR 200-1,200/year). For electrical devices such as razors or toothbrushes, an additional EUR 500-3,000 applies for CE testing. For multiple products, unit costs decrease significantly.

Q5Can I handle GPSR compliance for personal care products on Amazon.it myself, or do I need a service provider?

In principle, you can handle the CPNP registration and the Amazon mandatory fields yourself. However, the safety assessment must be carried out by a qualified Safety Assessor, and the EU Responsible Person must be permanently established and reachable in the EU - this is the hardest part for many non-European sellers. SpaceGoats offers complete GPSR and Cosmetics Regulation compliance from a single source: Safety Assessor, EU Responsible Person, CPNP registration, Italian translation, and CONAI registration, so you can focus on selling instead of paperwork.

GPSR (General Product Safety Regulation)Personal CareItaly 🇮🇹

Determine Economic Operator Role and Designate EU Responsible Person

Prepare Safety Assessment and Technical Documentation

Italian-Language Labeling and CONAI Packaging Obligations

Amazon.it GPSR Compliance Fields and Market Surveillance

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