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Private Label Cosmetics Compliance Guide 2026: FDA, EU & UK Checklists

A no-nonsense compliance map for private label brands selling into the US, EU and UK — what to file, when, and what it costs.

Key Facts · 2026-09-14

  • EU: every product needs a Compliant Product Information File (PIF), a Responsible Person, and CPNP notification before sale.
  • US: MoCRA requires facility registration, product listing, labelling (INCI, warnings) and adverse-event reporting — fully effective since 2024.
  • UK: post-Brexit, UK Responsible Person + UK Notification (UKNAP) replace EU RP/CPNP for Great Britain.
  • Budget $800-3,000+ per product for a safety assessment + notification, depending on complexity and market.
EU 1223/2009
Legal basis
MoCRA
US since 2024
$800-3,000
Per-product dossier
PIF 10y
EU retention

EU — Regulation 1223/2009 & CPNP

Before any EU sale you need: a Product Information File (PIF) (formula, safety report, manufacturing GMP, animal-testing declaration), a designated Responsible Person in the EU, and a CPNP notification. The PIF must be kept for 10 years after the last batch is sold. Microbiological and stability testing are expected for most products.

US — MoCRA

The Modernization of Cosmetics Regulation Act gives the FDA real authority. In practice you must: register the facility, list each product (with ingredients), meet labelling rules (INCI names, warnings, domestic contact), keep records of adverse events, and follow good manufacturing practice once the rule is finalised. 'Organic' and 'clean' claims remain FTC/AFP-adjacent and must be substantiated.

UK — UKCA / UKNAP

For Great Britain you need a UK Responsible Person and a UK product notification (via the UKNAP portal); Northern Ireland follows EU rules. The substantive safety duties mirror the EU regime.

Other markets at a glance

Checklist before you produce

  1. Lock the INCI formula and full ingredient specs.
  2. Commission a Certified Cosmetic Product Safety Report (EU/UK) or equivalent.
  3. Appoint a Responsible Person per market.
  4. File CPNP / UKNAP / MoCRA listing.
  5. Print compliant labels (INCI, warnings, RP contact, batch/PAO).

QuickOEM's partner factories work to ISO 22716 GMP and can supply the technical files your assessor needs.

Frequently Asked Questions

What is the difference between CPNP and MoCRA?
CPNP is the EU's cosmetic product notification portal under Regulation 1223/2009; MoCRA is the US law requiring FDA facility registration, product listing and adverse-event reporting.
Do I need a Responsible Person for the EU?
Yes. An EU-based Responsible Person must be appointed and hold the PIF before you can sell in the EU.
How much does compliance cost per product?
Typically $800-3,000+ per product for a safety assessment and notifications, more for complex or claim-heavy formulas.

Compliance-ready from day one

Match with ISO 22716 factories that supply the technical files your safety assessor needs.

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