Does GPSR Apply to Cosmetics? Handmade Soap Rules in the EU (2026)

Short answer: no — cosmetics, including handmade soap, are governed by their own dedicated EU law, the Cosmetics Regulation (EC) No 1223/2009, not by the GPSR's general regime. The General Product Safety Regulation (EU) 2023/988 (GPSR) is deliberately built as a safety net: under Article 2(1), where a product is subject to specific safety requirements under other EU law, the GPSR applies only to the aspects and risks those specific rules do not cover. For cosmetics, safety is covered comprehensively by Regulation 1223/2009 — a regime that is stricter than the GPSR, not lighter. If you sell handmade soap, bath bombs, lip balm, or shampoo bars to EU buyers, filling in a marketplace's GPSR fields and writing a generic risk assessment is not enough: you need a safety report signed by a qualified assessor, a designated responsible person, and a CPNP notification before the first sale.

Is handmade soap really a cosmetic?

Yes — soap meets the legal definition of a cosmetic product, and "handmade" or "all-natural" changes nothing. Article 2(1)(a) of Regulation 1223/2009 defines a cosmetic as any substance or mixture intended to be placed in contact with the external parts of the human body (skin, hair, nails, lips…) with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, or keeping them in good condition. Soap exists to clean skin, so it is squarely a cosmetic. There is no exemption for small batches, hobby sellers, or natural ingredients.

This deserves saying kindly but plainly, because it is the most common gap we see: careful soap makers do their GPSR homework — risk assessment, listing fields, labels — without realizing their product sits under a different, heavier law entirely. Where common handmade products actually fall:

Product	Cosmetic under Reg. 1223/2009?	Which regime applies
Handmade soap (bar or liquid)	Yes — cleans the skin	Cosmetics Regulation
Bath bomb, bath salts	Yes — skin contact, perfuming/cleaning	Cosmetics Regulation
Lip balm	Yes — lips are named in the definition	Cosmetics Regulation
Solid shampoo / conditioner bar	Yes — hair care	Cosmetics Regulation
Candle, wax melt	No — not applied to the body	GPSR (+ CLP hazard labelling)
Reed diffuser, room spray	No — treats the room, not the person	GPSR (+ CLP hazard labelling)
Pet shampoo	No — the definition covers the human body only	GPSR
Soap dish, ceramics, jewelry	No	GPSR

So does the GPSR apply to cosmetics at all?

Only at the margins — GPSR Article 2(1) makes it a fallback that steps aside wherever specific EU safety rules already cover the risk. The second subparagraph of Article 2(1) says that where products are subject to specific safety requirements under Union law, the GPSR applies only to the aspects and risks those requirements do not cover. Because the Cosmetics Regulation deals with cosmetic safety comprehensively — formulation, assessment, documentation, labelling, notification — your compliance work as a soap seller happens under Regulation 1223/2009, and pointing at a GPSR file will not satisfy an inspector.

What the GPSR era did change for you is marketplace enforcement: since 13 December 2024, Etsy, Amazon, and other platforms collect safety and traceability information for EEA-bound listings and take listings down when it is missing — see our guide on GPSR for Etsy sellers. You will still fill those fields for a soap listing; what belongs in them, though, comes from your Cosmetics Regulation compliance, not from a generic GPSR pack.

What does the Cosmetics Regulation require before the first sale?

Five things, all in place before the product is placed on the market: a responsible person, a safety report, a product information file, a CPNP notification, and compliant labelling.

Obligation	Legal basis	What it means for a soap maker
Responsible Person (RP)	Art. 4	Every cosmetic needs a designated legal or natural person established in the EU who answers for its compliance. An EU-based maker can be their own RP; a non-EU maker must appoint one by written mandate. Note this is a different, heavier role than the GPSR-style EU Responsible Person appointment for ordinary products.
Cosmetic Product Safety Report (CPSR)	Art. 10 + Annex I	A structured safety assessment of your exact formulation — Part A (safety information) and Part B (the assessor's signed conclusion).
Product Information File (PIF)	Art. 11	A file per product — description, CPSR, manufacturing method (GMP), proof of claimed effects — kept for 10 years after the last batch is placed on the market.
CPNP notification	Art. 13	Before placing on the market, the RP notifies the product electronically to the European Commission via the Cosmetic Products Notification Portal (CPNP).
Labelling	Art. 19	On container and packaging: RP name and address, nominal content, minimum durability date or period-after-opening, precautions, batch number, product function, and the full INCI ingredient list.

Who can write the safety assessment?

Not you, unless you hold the required diploma — Article 10(2) reserves the assessment for a person with a university qualification in pharmacy, toxicology, medicine, or a similar discipline (or one recognised as equivalent by a Member State). This is the step handmade sellers most often miss, and it cannot be templated around: no checklist, AI tool, or bought PDF substitutes for a qualified assessor's signature on your formulation. Expect a paid, per-recipe service — and note that changing the recipe (a new fragrance oil, a new colorant) means the assessment must cover the new version. Batch-to-batch of the same assessed recipe is fine; a new formulation is a new assessment.

What is NOT required for handmade cosmetics?

No CE marking, no pre-market approval, and no lab test of every batch — and a generic GPSR risk template is not a substitute for a CPSR. To keep the scope honest:

• CPNP notification is not an approval or a certificate. Nobody at the Commission "approves" your soap; notifying is mandatory, but responsibility stays entirely with the RP.
• CE marking does not apply to cosmetics. A CE logo on soap is meaningless (and misleading).
• Finished cosmetics sold to the final user sit outside CLP hazard labelling (Art. 1(5) of Regulation (EC) No 1272/2008) — but your candles, wax melts, and room sprays are not cosmetics, so they need CLP labels and GPSR compliance.
• A GPSR risk assessment does not satisfy Annex I. It is the right document for your non-cosmetic products and the wrong one for your soap.

Where does EUSellKit fit — and where does it honestly not?

EUSellKit does not support cosmetics: our document packs cover GPSR products, and a GPSR pack is the wrong document for soap. We would rather tell you that plainly than sell you paperwork an inspector will reject. If your product is a cosmetic, your path runs through a qualified safety assessor, a responsible person, a CPNP notification, and an Article 19 label — in that order.

Most handmade shops are mixed, though. If you also sell candles, wax melts, jewelry, ceramics, or accessories, those do fall under the GPSR, marketplaces actively enforce it — a missing field is enough to get a listing deactivated on Etsy — and that is exactly what we cover. Paste a listing into our checker: if it is in scope, you get a plain-English gap list and the documents to close it; if it is a cosmetic, we will say so instead of charging you for the wrong pack. Check your non-cosmetic products — €14

This guide is general information, not legal advice.