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Your own brand

Law and approval for your perfume

Whoever sells a perfume under their own name in the EU needs a responsible person, a safety assessment (CPSR), a product information file (PIF) and the CPNP notification before the first sale. Here you get the steps in the right order, who does what and what we take over.

General information, not legal advice. As of 13 October 2026.

Parfumfabrik: manufacturer of the perfume oils, wholesale and contract filling. Everything from one source.

Order a CPSRPrice and duration on the order page

Two worlds, two sets of rules.

The ingredient

Perfume oil

Chemicals law: REACH and CLP

  • Safety data sheet
  • Classification and labelling
  • Allergen list
  • IFRA statement

This applies to the oil itself. For every oil we provide the documents in the document centre.

The finished product

Finished perfume for consumers

Cosmetic product under the EU Cosmetics Regulation (EC) No 1223/2009

  • Responsible person
  • Safety assessment (CPSR)
  • Product information file (PIF)
  • CPNP notification
  • Labelling

This applies to you as the brand. The steps are listed below in the right order.

Terms

Terms in one sentence.
  • Responsible personPerson or company in the EU that answers for the product, usually the brand. Also called RP.
  • CPSRSafety report (Cosmetic Product Safety Report). Without it a cosmetic product may not be placed on the market.
  • PIFProduct information file: all documents on the product, to be kept for 10 years.
  • CPNPEU portal where cosmetics are notified before sale. A notification, not an approval.
  • GMP (ISO 22716)Good manufacturing practice: rules for clean, documented manufacturing and filling.
  • INCIInternational list of ingredient names, as shown on the label.
  • AllergensFragrance substances that must be listed individually on the label above a threshold.
  • IFRAFragrance industry association. Its standards limit fragrance ingredients by product type.
  • Safety data sheetData sheet for the oil with classification, handling, storage and transport under REACH.
  • UFI and poison centresThe UFI code links a hazardous mixture to its notification to the poison centres, which retrieve the formulation in an emergency.
Checklist

Ten steps in the right order.

0 of 10 done

  1. Appoint the responsible personArt. 4, 5Who: You
    What
    You decide who is responsible for the product in the EU. This is usually the brand itself.
    Why
    Every cosmetic product sold in the EU needs a responsible person based in the EU. Whoever places a product on the market under their own name or brand is the responsible person and carries the duties.
    Who
    You. The role can be transferred in writing to a service provider based in the EU. Whether Parfumfabrik takes over this role for you is settled in the quote, see “Who does what”.
    Document
    Appointment of the responsible person, or the written mandate if the role is transferred.
    Result
    Name and address appear on the label and in the CPNP notification.
  2. Gather formulation and raw material dataWho: You and us
    What
    You compile the complete formulation: perfume oil, alcohol, water and additives, each with a specification.
    Why
    It is the basis for the safety assessment, the product information file and the labelling.
    Who
    You. For each of our oils we supply the safety data sheet, the IFRA statement and the allergen list.
    Document
    Formulation sheet with proportions, safety data sheet, IFRA statement, allergen list, specifications of the other ingredients.
    Result
    A complete formulation in which every ingredient is documented.
  3. Manufacture to GMP (ISO 22716)Art. 8Who: Manufacturer
    What
    Manufacturing and filling follow good manufacturing practice (GMP), with batch documentation.
    Why
    The product must be manufactured to GMP. The declaration belongs in the product information file.
    Who
    Whoever manufactures and fills, with contract filling that is us. We fill to GMP-oriented standards (ISO 22716).
    Document
    GMP declaration of the manufacturer, batch record.
    Result
    Every batch is documented and traceable.
  4. Safety assessment (CPSR)Art. 10, Annex IWho: Specialist
    What
    A safety assessor reviews your product and writes the safety report (Cosmetic Product Safety Report).
    • Part A, safety information: composition, physical and chemical properties, stability, microbiological quality, impurities, packaging, use and exposure, toxicological profile, undesirable effects
    • Part B, safety assessment: conclusion, warnings, reasoning, qualification and signature of the assessor
    Why
    Without a CPSR the product may not be placed on the market.
    Who
    The assessor holds a university degree in pharmacy, toxicology, medicine or a comparable field. You commission them. For fragrances from our range you can order the CPSR from us: external specialists prepare it, we run data collection and process. Order a CPSR
    Document
    The CPSR with Part A and Part B.
    Result
    An assessment with a conclusion and the warnings for your label.
  5. Product information file (PIF)Art. 11Who: You
    What
    You compile the documents on your product:
    • Product description
    • CPSR
    • Description of the manufacturing method with GMP declaration
    • Proof of effect for advertising claims
    • Information on animal testing
    Why
    Authorities can request the file at any time.
    Who
    The responsible person. They keep the file at their address and make it available to authorities, in a language the authority understands.
    Document
    The PIF as a folder. Keep it for 10 years from the day the last batch was placed on the market. PIF assistant (prototype)
    Result
    A complete folder that stays available for 10 years.
  6. LabellingArt. 19Who: You
    What
    On bottle and carton:
    • Name and address of the responsible person
    • Country of origin for imports
    • Nominal content
    • Minimum durability or period after opening (PAO symbol), no date if durability exceeds 30 months
    • Warnings, batch number, function
    • Ingredient list (INCI): the fragrance composition as “Parfum”, declarable fragrance allergens individually
    Why
    Mandatory for every cosmetic product. Allergens are listed from 0.001 % in leave-on products and from 0.01 % in rinse-off products. In Germany everything is in German.
    Who
    You, using the allergen data of your oil. We check your print data free of charge.
    Document
    Label draft with all mandatory information.
    Result
    Label and carton are complete and legible.
  7. New allergen list (Regulation (EU) 2023/1545)Who: You
    What
    The number of fragrance allergens that must be declared rises from 26 to more than 80 substances.
    Why
    The new list applies to newly marketed products from 31 July 2026 and to all products from 31 July 2028. For new brands it therefore applies now. Please confirm dates and scope with a specialist.
    Who
    You label. For every oil we provide the allergen data in the document centre. Find documents
    Document
    Allergen list of the oil in its current version.
    Result
    Your label names all declarable allergens under the new list.
  8. CPNP notificationArt. 13Who: You or a provider
    What
    Before the sale you notify the product in the EU portal CPNP (Cosmetic Products Notification Portal). The notification is free of charge. Details required:
    • Category and product name
    • Name and address of the responsible person, location of the PIF
    • Country of origin for imports, member state of placing on the market, contact person
    • Nanomaterials yes or no, CMR substances
    • Frame formulation (for emergency treatment by poison centres)
    • Photo or scan of the labelling
    Why
    Mandatory before placing on the market. The CPNP is a notification, not an approval: cosmetics are not approved by authorities in the EU.
    Who
    The responsible person notifies themselves (EU login required) or commissions a service provider. We notify on request on your behalf. The terms are stated in the quote.
    Document
    Confirmation of the notification from the CPNP.
    Result
    The product is notified. With CPSR, PIF and labelling it may be sold in the EU.
  9. Advertising claims and animal testingArt. 18, 20Who: You
    What
    Claims such as “skin friendly” must be provable. Animal testing for cosmetics is banned in the EU.
    Why
    Evidence belongs in the product information file.
    Who
    You. A specialist can help with the wording.
    Document
    Proof of effect and information on animal testing in the PIF.
    Result
    Label and advertising state only what you can prove.
  10. After the saleArt. 23Who: You
    What
    You report serious undesirable effects to the competent authority (cosmetovigilance), document formulation changes and new batches and update the CPSR when something changes.
    Why
    The responsible person remains responsible for the product as long as it is sold.
    Who
    The responsible person.
    Document
    Reports, batch records, updated CPSR and PIF.
    Result
    Your documents are up to date.

You can tick off steps. This is stored in this browser only.

Tasks

Who does what?

Tasks and who handles them
TaskParfumfabrikYou (brand)Specialist, authority
Manufacture perfume oil and perfumeParfumfabrikWe, as manufacturer of the oils and perfumesYounot applicableSpecialistnot applicable
Safety data sheet, IFRA statement and allergen list for the oilParfumfabrikWe, for every oilYouYou use them for formulation and labelSpecialistnot applicable
Manufacture and filling to GMPParfumfabrikWe, for contract filling and private labelYouYou, if you fill yourselfSpecialistnot applicable
Safety assessment (CPSR)ParfumfabrikWe run data collection and process, for fragrances from our rangeYouYou order and provide your product dataSpecialistA safety assessor prepares the assessment
Responsible person and CPNP notificationParfumfabrikOn request, for contract filling and private label. The terms are stated in the quoteYouOtherwise you yourself or a commissioned provider in the EUSpecialistThe CPNP receives the notification, there is no approval
Compile the PIF and keep it for 10 yearsParfumfabrikDocuments and batch records for the productYouThe responsible person. If we take over the role, we take over the PIF as well.Specialistnot applicable
LabellingParfumfabrikWe check your print data free of chargeYouYou are responsible for the contentSpecialistnot applicable
Reporting serious undesirable effectsParfumfabriknot applicableYouYou, as the responsible personSpecialistThe competent authority receives the report

Whether we take over the role of the responsible person and the CPNP notification is stated per route in the quote.

Often forgotten

More duties.

Check each of these with your specialist.

  • Alcohol

    Perfume usually contains denatured ethanol. Alcohol tax law and customs rules apply, for example when using tax-free alcohol.

  • Shipping

    Perfume with a high alcohol content is flammable. Dangerous goods rules (ADR, IATA), special packaging and air freight restrictions apply.

  • Packaging Act

    Registration with LUCID and participation in a dual system for sales packaging.

  • Fill quantity and price display

    Pre-packaged goods law and unit price display in consumer sales.

  • Trademark law

    Search your name before you start.

  • Markets outside the EU

    The United Kingdom and Switzerland require their own responsible person and their own notification. The EU CPNP does not apply there.

  • Chemicals law for the oil

    Safety data sheet, classification, UFI code and notification to poison centres for hazardous mixtures.

Proof

Certifications.

What is documented for our oils and what we deliberately do not claim.

What we can document

Documents and proof, with status and meaning
DocumentStatusWhat it means
IFRA compliance statementStatusFor every oil, as a PDF.MeaningConfirms that the oil meets the IFRA standard. Maximum levels apply per product category. IFRA itself does not issue certificates.
Safety data sheet (SDS)StatusFor every oil, as a PDF.MeaningClassification, handling, storage and transport under REACH.
Allergen listStatusFor every oil, as a PDF.MeaningDeclarable fragrance substances, for your label and product documentation.
Batch documentationStatusOn request. Request documentsMeaningEvery batch is documented, and we archive retention samples for five years.
CPSR (safety assessment)StatusFor fragrances from our range. Order a CPSRMeaningRequired if you place a cosmetic product such as a perfume on the market.
Production standardStatusGMP-oriented (ISO 22716)MeaningWe list a certificate here as soon as one is available.
Customer reviewsStatus4.35 out of 5 on Trusted ShopsMeaningVerified reviews from customers. This is not a product certificate.

What we do not claim

  • IFRA compliant, not IFRA certified

    IFRA does not certify companies. We therefore say that our oils meet the IFRA standard, and we back it up with the compliance statement for each oil.

  • Nothing without a document

    If we name something here, you can ask for the matching document. What is not available yet is not listed.

  • IFRA does not replace a safety assessment

    For a finished cosmetic product you also need a CPSR. The compliance statement for the oil is only one input.

You find the documents for an oil in the document centre. You order the safety assessment for your perfume under Order a CPSR.

Our part

What we take off your hands.

Order a CPSR Request a quote View documents for an oil
  • We make perfume oil and perfume ourselves.
  • With every oil: safety data sheet, IFRA statement and allergen list.
  • CPSR for fragrances from our range: external specialists prepare it, we run data collection and process. €107.10 incl. VAT per fragrance, usually 3 to 5 weeks.
  • We check print data for the label free of charge.
  • Responsible person and CPNP notification: on request, the terms are stated in the quote.
Questions

Short answers.

More on documents and safety assessment in the help centre.

Do I need a CPNP notification for perfume oil?

No, not for the ingredient. For the finished perfume, yes. CPNP notification step by step (German).

Is the CPNP an approval?

No. It is a notification. Cosmetics are not approved by authorities in the EU. Guide to safety and regulation.

What does it cost?

The CPSR through us costs €107.10 incl. VAT per fragrance. Further costs, for example for the role of responsible person or the CPNP notification by us, are stated in the quote.

How long does it take?

The CPSR takes usually 3 to 5 weeks. How long all steps take together until the first sale depends on your formulation and is stated in the quote.

Who is liable?

The responsible person. Whoever sells a product under their own name usually is that person. This is not legal advice. Duties and liability in the blog (German).

Does this also apply to room fragrance or candles?

Cosmetics law does not apply. Chemicals law and product safety do. The CPSR exists only for cosmetic products.

Do I need a cosmetics business licence?

We do not give legal information on this. Please ask a specialist in cosmetics law.

Tools and further pages

Go deeper in the blog

General information, not legal advice. As of 13 October 2026. Have the details checked by a specialist before you act.