Digital Product Passport for cosmetics

No. No delegated act under the Ecodesign Regulation covers cosmetics. The first working plan of 16 April 2025 does not list them among the priority product groups. What is mandatory are the older rules of the Cosmetics Regulation. They cover the ingredient list on the pack, the responsible person, the product information file and the notification. A passport puts all of that where a phone can read it. The label is what makes it worth having. Whatever no longer fits on the tube fits on the page behind the code. In Transpareo that page appears in every market language and carries your brand.

Yes, and more heavily than most people expect. Whoever brings a cosmetic product into the EU from a third country places it on the market. So the importer is the responsible person, unless it designates someone else in writing. It owes the product information file, the safety assessment and the notification. Agree in the supply contract who delivers the INCI data, the allergen figures and the safety assessment. Fix the format too, before the first pallet moves. With a supplier request in Transpareo, your manufacturer fills in the data, and you review every value.

It is a natural or legal person in the Union, named on the label. A distributor becomes the responsible person only when it sells under its own name and brand. The same applies when it changes the product in a way that may affect compliance. Otherwise the role stays with the manufacturer, the importer or a designated third party. The role carries a real liability. So settle it in writing.

Yes. The notification goes to the Commission’s portal before the product is placed on the market. It serves poison centres and market surveillance, and nothing public replaces it. A passport sits next to it and serves the buyer in the shop. Both draw on the same data. Keep the formulation, the frame formulation and the responsible person in Transpareo, and the details for both sit in one place.

A Commission regulation of 26 July 2023 raised the number of fragrance allergens to be named individually from 24 to roughly 80. The threshold is 0.001 per cent in leave-on and 0.01 per cent in rinse-off products. Products without the extended declaration could be placed on the market only until 31 July 2026. They may be made available only until 31 July 2028. The real work sits in the supplier declarations behind the label. Few brands hold the fragrance composition themselves. With a supplier request in Transpareo, the fragrance house fills in its figures.

Not as a substitute. The list belongs on the container or packaging. Where that is impossible in practice, it goes on a leaflet, label, tag or card. A hand-and-book symbol on the pack points to it. The simplification proposal adds no digital route for cosmetics, and the known points of the agreement leave that as it is. A passport carries the same list where it is readable. In Transpareo it appears at full size, with the function of each substance and in 40 languages. It stays current even when the pack cannot be reprinted. The pack stays the legal carrier, and the passport is the copy people actually read.

No. Cosmetics law prescribes no identifier, only the batch number and the particulars on the label. If you have a GTIN, Transpareo turns it into a GS1 Digital Link that other systems resolve too. That is convenient, because retail already carries the number. Without one, Transpareo issues a unique identifier of its own, and the QR code leads to the same passport.

Cosmetics law splits the information in two. The public must be able to see the composition easily, and the data on undesirable effects as well. Quantities count only for hazardous substances. The product information file stays with the responsible person and opens to the authority. In Transpareo every data field has its own visibility. The public tier appears without a login. The safety assessment, the supplier declarations and the certificates sit behind logged access. So the passport can be the means by which you make the public information accessible.

The product information file has to be kept for ten years, counted from the last batch. A passport carrying the same data sensibly outlives the last jar as well. Otherwise the printed code leads nowhere. So ask every provider what happens to your passports after a cancellation. With Transpareo, published passports stay reachable through a permanent address. Our provider checklist names more questions worth asking.

Member states set the penalties. They have to be effective, proportionate and dissuasive. The fine is rarely the expensive part. Market surveillance can order a withdrawal or a recall. In cosmetics a recall over a missing allergen declaration is a public event. It outlasts the corrective action by years. Getting the ingredient data right once costs less than explaining it later.

For the ingredient list, not as things stand. The proposal of 8 July 2025 replaces the Commission glossary with an internationally recognised nomenclature. It reworks the listing of colourants, preservatives and UV filters and the handling of CMR substances. It wanted to drop the separate pre-notification for nanomaterials. Parliament and Council agreed politically on 16 June 2026. Under the deal the nanomaterial notification stays, and products with CMR substances phase out faster. The final text is not in the Official Journal yet. So treat every detail as provisional. Neither the proposal nor the known points of the deal move the mandatory particulars into a QR code.