CPSR Part A Safety Information Checklist Before You Notify

The EU is the one market where a maker genuinely cannot self-file their way to compliance, and the reason comes down to one document: the Cosmetic Product Safety Report. Under Regulation (EC) No 1223/2009, you notify through the CPNP portal, but before that notification means anything, you need a Responsible Person established in the EU, a Product Information File, and a CPSR signed by a qualified safety assessor. Part A of that report is the raw material the assessor needs to actually do their job, and gathering it yourself before you approach an assessor saves real time and money.

Why Part A exists

A safety assessor isn't evaluating your product on vibes or on a generic ingredient list. They're building a documented, defensible safety case, and Part A is essentially the evidence file behind that case. If you show up with gaps in Part A, the assessor either has to chase the missing data themselves, which costs you time and often money, or they can't sign off at all. Coming prepared is the single highest-leverage thing you can do before engaging an assessor.

The checklist

Work through this before your first conversation with a safety assessor:

• Quantitative and qualitative formula composition. Every ingredient, by INCI name, with its exact percentage, not a range. This is the foundation everything else builds on.
• Physical and chemical characteristics of the finished product. pH, appearance, relevant physical properties that affect how the product behaves on skin.
• Physical and chemical characteristics and stability of each raw material. Not just what's in the formula, but documentation on each individual ingredient's own properties.
• Microbiological quality. Both the raw materials and the finished product need microbiological specifications, particularly relevant for water-containing formulas.
• Impurities, traces, and packaging material information. Any known impurities in raw materials, and information about the packaging that will contact the product, since packaging can interact with a formula over its shelf life.
• Normal and reasonably foreseeable use. How the product is actually meant to be used, and realistically how it might be used even outside the label instructions, since safety assessment has to account for foreseeable misuse, not just ideal use.
• Exposure to the product. How much product a consumer is realistically exposed to, how often, and by what route, factors that feed directly into the toxicological calculations the assessor performs.
• Exposure to the substances. Building on product-level exposure, this breaks down exposure at the level of individual ingredients.
• Toxicological profile of the substances. The assessor needs toxicological data on the ingredients themselves, which is often where existing published safety assessments on common ingredients can be referenced rather than generated from scratch.
• Undesirable effects and serious undesirable effects. Any known history of adverse reactions associated with the formula or its ingredients.
• Information on the cosmetic product. Other relevant product-level information not captured elsewhere, including any existing data from similar products.

Where makers most often fall short

Two spots trip people up more than the rest of the list combined:

• Stability data. Makers often have a "shelf life" figure they've settled on informally, based on similar products or general industry convention, without an actual stability study behind it. An assessor needs real data, or at minimum a documented rationale, not an assumption carried over from a different formula.
• Microbiological quality. This gets skipped most often by small makers producing in low volumes, on the assumption that a clean workspace is sufficient documentation. It isn't. Microbiological specifications and, where relevant, challenge testing results are part of what the assessor is looking for.

Getting organized before you talk to an assessor

A simple way to approach this is to build a single folder, physical or digital, per product, with each Part A element as its own labeled section. Even if a section is thin (a few sentences on normal and foreseeable use, for instance) having the structure in place means you can see exactly what's missing before an assessor tells you.

Cosmetic Comply doesn't replace the safety assessor's sign-off, that's a professional judgment call the regulation specifically requires, but the ingredient-level work it does, mapping every component to INCI name, CAS number, and concentration, and flagging anything near a restricted threshold, produces exactly the kind of organized composition data that feeds directly into Part A and makes the assessor's job faster.