CPSR for Baby Products: What Data Your Manufacturer Should Provide

Before finalizing any baby product formulation or packaging, brand owners must ensure the manufacturer provides adequate safety and compliance documentation. For the EU and UK markets, a Cosmetic Product Safety Report (CPSR) is mandatory — and for Mom & Baby brands, the scrutiny is even higher due to infants’ sensitive skin. Understanding what data to request from your producer helps you avoid costly relabeling, re-testing, or shipment delays.

What Is a CPSR and Why It Matters for Baby Products

The CPSR is a scientific assessment required under EU Regulation (EC) No 1223/2009 for all finished cosmetics sold in the EU and UK. For baby-specific items — such as diaper creams, body lotions, cleansers, and oils — evaluators expect deeper toxicological reviews and more conservative exposure calculations.

• Part A – Safety Information: Ingredient data, raw material certificates, purity and contamination limits, microbiological specs, packaging compatibility.
• Part B – Safety Assessment: Expert toxicologist evaluation, product use scenario, exposure levels, risk characterization, and final conclusion.

Core Data Your Manufacturer Should Supply

Collect these documents before initiating CPSR drafting. Missing data is the number one reason reports are rejected or delayed.

1. Ingredient and Raw Material Documentation

• Complete INCI list and exact concentrations
• Supplier Certificates of Analysis (COA) for every raw material
• Allergen statements (especially for fragrance or botanical extracts)
• Vegan or no animal-testing declarations (if relevant to your brand)
• Heavy metal and preservative test results (infant tolerance limits are lower)

2. Formula and Product Safety Data

• Microbiological challenge test report (efficacy of preservatives)
• Stability and compatibility tests under various temperatures
• pH and viscosity data, since extreme values can irritate baby skin
• Dermatological testing or irritation patch test summary

3. Packaging and Batch Data

• Material composition of bottle, cap, pump, or tube (for extractables/leachables)
• Packaging compliance statement confirming contact safety
• Batch manufacturing record (traceability and production controls)
• Microbiological controls for filling lines

Verification and Evidence Table

Practical Steps for Buyers

1. Ask for a draft ingredient deck with full percentages early in development.
2. Verify that all raw materials have valid COAs dated within 12 months.
3. Ensure your CPSR consultant or appointed Responsible Person reviews the safety dossier before artwork approval.
4. Build compliance checkpoints into your supplier contract to avoid re-testing later.

Common CPSR Gaps in Baby Product Projects

• Unverified botanical extracts: Natural origin does not mean automatically safe; toxicity data is still required.
• Incomplete preservative validation: Weak challenge tests lead to microbial growth review failures.
• Missing packaging material info: Without migration data, assessors may reject the report.
• No irritation test summary: This is critical for “dermatologically tested” claims.
• Outdated COAs or SDS: Documents older than a year can trigger audit issues.

FAQ: CPSR for Baby Product Sourcing

1. Who is responsible for the CPSR?

The Responsible Person (RP) for the EU or UK market owns the CPSR submission, but your manufacturer must provide the raw data and test results used in it.

2. Is the CPSR required for private label baby cosmetics?

Yes. Even if you rebrand an existing formula, the CPSR must reflect your product name, packaging, and intended claims.

3. How long does it take to get a CPSR approved?

Typically 2–4 weeks, provided all ingredient and test documentation is available and complete.

4. Can natural or organic certification replace a CPSR?

No. Certifications such as COSMOS or ECOCERT are not substitutes for a regulatory safety assessment under EU/UK laws.

5. How often should the CPSR be updated?

Whenever formulation, packaging, or supplier materials change — or at least every five years.

Final tip: Build your CPSR data pack with your manufacturer before initiating artwork design; this ensures your baby care line meets all market-entry safety requirements.

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Hi, I'm Alex Zong, hope you like this blog post.

With more than 20 years of experience in OEM/ODM/Private Label Cosmetics, I'd love to share valuable knowledge related to cosmetics & skincare products from a top-tier Chinese supplier's perspective.