Chemicals
DPP for Cosmetics: CPNP, PIF and ESPR
DPP for cosmetics: Regulation 1223/2009, the responsible person, CPNP notification, PIF and INCI data turned into a passport, and how Turkish exporters prepare
The cosmetics sector is not unprepared for the Digital Product Passport. Regulation (EC) 1223/2009 on cosmetic products requires a responsible person established in the EU, a CPNP notification before placing on the market, a comprehensive Product Information File (PIF) and an INCI ingredient label. What is missing is machine-readable data reachable from a single carrier.
ESPR neither excludes nor prioritises cosmetics. The real pull towards the passport comes from two sides: PPWR, which directly affects cosmetic packaging, and green-claims rules, which tie "natural", "clean" and "vegan" claims to evidence.
Today's regime and its place in the passport
| Obligation | Today | Passport counterpart and tier |
|---|---|---|
| Responsible person (established in the EU) | Name and address on the label | Identity field, public |
| CPNP notification | Before placing on the market, online portal | Reference number, authority tier |
| Product Information File (PIF) | Held by the responsible person, open to authorities | Document links, authority tier |
| INCI ingredient list | On the pack, descending order of weight | Ingredient field, public |
| Allergen declaration | Named on the label | Ingredient field, public |
| Batch number, PAO or expiry date | On the pack | Identity and use field, public |
| Warnings and instructions for use | On the pack | Safety field, public |
The passport recreates none of this; the structured ingredient and safety information already in the PIF is opened to the public or to authorities by access tier. For the substance declaration, see DPP for chemicals, REACH and SCIP.
Where cosmetics sit in ESPR
Cosmetics are not on ESPR's exclusion list, nor in the 2025–2030 working plan. The Cosmetics Regulation's own revision is being prepared, and a partial, CLP-style digitalisation of label information has been debated since 2024. As of September 2026 no digital labelling rule has been adopted; the INCI list stays on the pack. See are chemical products in scope of ESPR.
The real pull: PPWR and green claims
Cosmetic packaging is small, multi-layered and part of the brand identity; PPWR targets exactly that: recyclability grade, recycled content in plastic packaging, an empty-space limit and a harmonised label. See DPP and PPWR for packaging and PPWR-compliant packaging labelling.
The second pull is claims. "Natural", "clean", "vegan", "microplastic-free" and "PFAS-free" are the language of cosmetics marketing, and green-claims rules demand evidence for each. The passport presents the INCI list, certificate and test result behind the claim from one QR. See the Green Claims Directive and greenwashing and the PFAS restriction and passport declarations.
What a cosmetics passport carries
- Ingredients: INCI list, allergens, restricted-substance declaration, preservative system.
- Use and safety: warnings, instructions for use, PAO or expiry date, target user.
- Identity: responsible person, manufacturer, batch number, CPNP reference (authority tier).
- Packaging: material composition, recyclability grade, recycled content, refill compatibility.
- Claims and certificates: natural or organic certificate, vegan declaration, no-animal-testing declaration; each with an evidence link.
Batch granularity works almost as a requirement here: recalls, shelf life and complaint handling all rest on the batch number. See choosing granularity and product recalls and the DPP.
Preparation for Turkish cosmetics exporters
Although Türkiye's cosmetics legislation parallels the EU regulation, the product notification to TİTCK and the CPNP notification are separate procedures, and the EU responsible person must be established in the EU. See economic operators and their responsibilities.
- Keep the PIF as structured data; let INCI, allergen and safety information flow from one source to label and passport alike.
- Settle the data-sharing agreement with the responsible person: who opens the CPNP reference and PIF access to the passport's authority tier?
- Request packaging composition and recyclability grade from the packaging supplier in structured form.
- Link an evidence document to every claim in the product record; remove any claim without evidence from the label.
- Set up batch-level QR codes and the resolver architecture; manage a content version per market language.
For market-entry steps, see the Turkish exporter guide.
Frequently asked questions
Is a Digital Product Passport mandatory for cosmetic products?
No. Cosmetics are in scope of ESPR but not in the 2025–2030 working plan, and the Cosmetics Regulation revision contains no adopted digital labelling rule yet. The demand comes from PPWR, green-claims rules and retailers.
Do the CPNP notification and the PIF replace the passport?
No; but they fill most of the passport's ingredient, safety and identity fields. The passport presents that data to consumers and inspectors through access tiers.
Should the INCI list in a cosmetics passport be public?
Yes; the INCI list is already public on the label. Concentrations and formulation detail stay in the PIF and are presented only in the authority tier.
