Digital Product Passport for cosmetics

No. No delegated act under the Ecodesign for Sustainable Products Regulation covers cosmetics, and the first working plan of 16 April 2025 does not list them among the priority product groups. What is mandatory is the older set of duties in Regulation (EC) No 1223/2009 - the ingredient list on the pack, the responsible person, the product information file and the notification. A passport is the place to put all of that where a phone can read it, not a new legal obligation. What makes it worth having anyway is the label - everything that no longer fits on the tube fits on the page behind the code, in every market language, with your branding on it.

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, and under Art. 4(5) the importer is the responsible person unless it designates someone else in writing. That means the product information file, the safety assessment and the notification, not just customs paperwork. Agree in the supply contract who delivers the INCI data, the allergen figures and the safety assessment, and in which format, before the first pallet moves.

The responsible person is one natural or legal person established in the Union, named on the label (Art. 4 and Art. 19(1)(a)). A distributor becomes the responsible person only when it places the product on the market under its own name or brand, or modifies it in a way that affects compliance (Art. 4(6)). Otherwise the role stays with the manufacturer, the importer or a designated third party. It is a real liability, not a mailbox, so settle it in writing.

Yes. The notification under Art. 13 goes to the Commission’s portal and serves poison centres and market surveillance; it is not replaced by anything public. A passport sits next to it and serves the buyer in the shop. The good news is that both draw on the same data, so once the formulation, the frame formulation and the responsible person are maintained in one place, the notification and the passport stop being two separate data-entry jobs.

Commission Regulation (EU) 2023/1545 of 26 July 2023 raised the number of fragrance allergens that have to be named individually in the ingredient list from 24 to roughly 80, above 0.001 per cent in leave-on and 0.01 per cent in rinse-off products. Products that do not carry the extended declaration could be placed on the Union market only until 31 July 2026 and may be made available only until 31 July 2028. In practice the work is not the label but the supplier declarations behind it, because most brands do not hold the fragrance composition themselves.

Not as a substitute. Art. 19(1) requires the ingredient list on the container or packaging, and the only relief the regulation gives is Art. 19(2) - where that is practically impossible, the list goes on an enclosed or attached leaflet, label, tape, tag or card, referred to by the hand-and-book symbol of Annex VII. The targeted revision that Parliament and Council agreed in June 2026 does not add a digital route for cosmetics either. What a passport does is carry the same list where it is readable - at full size, with the function of each substance and the allergen thresholds, in the 24 official EU languages and 16 more - and keep it current when the pack cannot be reprinted. The pack stays the legal carrier; the passport is the copy people actually read.

No. Cosmetics law prescribes no identifier at all, only the batch number and the particulars of Art. 19. If you have a GTIN, the identifier in Transpareo becomes a GS1 Digital Link that other systems resolve too, which is convenient because retail already carries the number. Without one the product gets a unique Transpareo identifier, and the QR code leads to the same passport.

Cosmetics law splits the information in two. The pack and Art. 21 govern what the public may see - the ingredient list, the qualitative and, for hazardous substances, the quantitative composition, and the data on undesirable effects. The product information file under Art. 11 stays with the responsible person and is opened to the competent authority, not to the buyer. In Transpareo, visibility is a property of every data field, so the public tier appears without any login and the safety assessment, the supplier declarations and the certificates sit behind logged access.

The product information file has to be kept for ten years after the last batch was placed on the market (Art. 11). A passport that carries the same data sensibly outlives the last jar as well, otherwise the link printed on it goes nowhere. So ask any provider what happens to your passports after a cancellation - with Transpareo, published passports stay reachable through a permanent address, and our provider checklist names the further questions worth asking.

Regulation (EC) No 1223/2009 leaves the penalties to the member states but requires them to be effective, proportionate and dissuasive. The expensive part is rarely the fine. A market surveillance authority can order withdrawal or recall, and in cosmetics a recall over a missing allergen declaration is a public event that outlasts the corrective action by years. Getting the ingredient data right once is cheaper than explaining it later.

Not for the ingredient list. The proposal of 8 July 2025 deletes the Commission’s glossary of common ingredient names and points the labelling rule at an internationally recognised nomenclature instead, adds a procedure for listing colourants, preservatives and UV filters, clarifies how substances classified as CMR are handled and removes the separate nanomaterial pre-notification. Parliament and Council agreed politically on 16 June 2026 and the final text is not in the Official Journal yet, so treat every detail as provisional. Nothing in it moves the mandatory particulars off the pack and into a QR code.