EU Cosmetics Rules for Hotel Toiletries: Who Does What
Hotel toiletries are cosmetics in the EU, so an EU-based Responsible Person must hold a Product Information File with a safety report and notify each product on the CPNP before supply. The manufacturer supplies the formula, INCI and manufacturing documentation; the hotel group, importer, distributor or a service provider takes the Responsible Person role.
In the EU, hotel shampoo, shower gel, body lotion and hand wash are cosmetic products under Regulation (EC) No 1223/2009. Before they reach a guest room, an EU-based Responsible Person must hold a Product Information File containing a Cosmetic Product Safety Report, notify each product on the CPNP and make sure the label is correct. The manufacturer supplies the technical inputs; the Responsible Person signs off.
This guide explains how that division of work operates for hotel groups, importers and distributors buying from a manufacturer outside the EU. For country-specific notes on labels, buyers and shipping, see our Europe hotel amenities hub.
Are hotel toiletries really cosmetics?
Yes. A product intended to be placed on the skin or hair to clean, perfume, protect or keep it in good condition is a cosmetic, and that covers almost everything in a hotel bathroom: shampoo, conditioner, shower gel, 2-in-1, body lotion and hand wash. It does not matter that the guest does not pay for the product separately. Supplying it in the course of a commercial activity is generally treated as making it available on the market, so the full rules apply to complimentary amenities just as they do to retail products.
The Responsible Person
Every cosmetic placed on the EU market must have a designated Responsible Person established in the EU. For products manufactured outside the EU, the importer is the Responsible Person by default, unless another EU-based person is appointed in writing and accepts the role. In practice, that may be:
- the hotel group itself, if it has an EU entity that imports the goods
- a distributor or importer that supplies many hotels
- a specialist regulatory service provider appointed by the brand owner
The Responsible Person's name and address appear on the label, and that person must be able to answer questions from national authorities. A manufacturer in India cannot fill this role from outside the EU. Harrods Health is not an EU Responsible Person; we support whoever is.
The Product Information File and safety report
The Responsible Person must keep a Product Information File (PIF) for each product, available to authorities at the address on the label. The PIF typically contains:
- a description of the product
- the Cosmetic Product Safety Report (CPSR), prepared by a qualified safety assessor
- a description of the manufacturing method and a statement of compliance with good manufacturing practice
- proof of any claimed effect, where the nature of the claim requires it
- data on any animal testing related to the product or its ingredients
The CPSR has two parts. Part A gathers the safety information: quantitative formula, physical and chemical characteristics, stability, microbiological quality, impurities, packaging, normal use, exposure and toxicological profiles of ingredients. Part B is the assessor's conclusion, warnings and reasoning. The assessor works from data the manufacturer provides, so the quality of that data decides how quickly the report can be completed.
CPNP notification
Before the product is placed on the market, the Responsible Person notifies it through the Cosmetic Products Notification Portal (CPNP), an EU-wide online system. The notification includes the product category, name, the Responsible Person's details, country of origin, the member state where it is first placed on the market, the presence of any substances in nanomaterial form, and the frame formulation or exact formulation. One notification covers all member states, but each product variant, such as a different scent, is usually notified separately.
Labelling
The label on the container and outer packaging must show, among other things:
- the name and address of the Responsible Person
- country of origin, for imported products
- nominal content by weight or volume
- date of minimum durability or, for longer-lasting products, the period after opening symbol
- precautions for use, where needed
- the batch number
- the function of the product, unless clear from its presentation
- the list of ingredients, using INCI names
Member states decide which language or languages the label information must be in. INCI names are used in their standard form across the EU. There are limited allowances for very small packs, such as placing some information on an enclosed leaflet or tag, but these need careful handling. Fragrance allergens above set concentrations must be named individually in the ingredient list.
Who does what
| Task | Manufacturer (Harrods Health) | Responsible Person / importer |
|---|---|---|
| Formula and INCI list | Supplies | Reviews and holds in PIF |
| Manufacturing method and GMP information | Supplies | Holds in PIF |
| Stability and microbiological data | Supplies test data available or agreed | Passes to safety assessor |
| Cosmetic Product Safety Report | Provides inputs | Commissions from a qualified assessor |
| CPNP notification | None | Completes before supply |
| Label content and languages | Prints approved artwork | Approves wording and languages |
| Post-market duties and authority questions | Supports with batch records | Handles |
What a good manufacturer should supply
For each product, ask your manufacturer for the full INCI list with percentages for the safety assessor, specifications, information on raw material suppliers and their safety documents, stability and preservative efficacy information where available, packaging specifications, and a description of the manufacturing process and quality controls. We supply ingredient lists and manufacturing documentation on request, and formulas can be supplied as dermatologically tested with reports on request.
Our facility is GMP-compliant and ISO certified, with a state FDA cosmetic manufacturing licence, an AYUSH licence and US FDA registration. Details are on our quality and certifications page. If you want to compare formats before you start, browse our hotel amenities collection or read about our hotel toiletries service.
Planning the timeline
The most common delay is treating compliance as the last step. If the safety assessment starts only after production, finished goods can sit in a warehouse. A better sequence is:
- Agree formats, scents and target countries.
- Appoint the Responsible Person and confirm label languages.
- Send formula data to the safety assessor while samples are evaluated.
- Approve artwork with the Responsible Person's details and the final INCI list.
- Complete CPNP notification before goods are released for supply.
Changing a scent or an ingredient later usually means updating the PIF and the notification, so lock the formula before you print. Our custom packaging team can hold artwork until the wording is final.
Halal and other voluntary standards
Some hotels, especially those welcoming many guests from Muslim-majority countries, ask for Halal-certified toiletries. Halal certification is voluntary and sits on top of the EU rules, not in place of them. We are Halal certified; see our guide to Halal hotel toiletries.
Rules change, and member states differ on language and enforcement. Always confirm the current position with your Responsible Person, importer or a regulatory consultant. For shipping and documents, see our fulfilment and export page.
Frequently asked questions
Can a manufacturer in India be the EU Responsible Person?
No. The Responsible Person must be established in the EU. The importer, a distributor, the hotel group's EU entity or an appointed service provider takes on the role, supported by the manufacturer's documentation.
Do free amenities need CPNP notification?
Generally yes. Supplying a cosmetic to guests as part of a commercial service is usually treated as placing it on the market. Check the position for your products with your Responsible Person.
Does each scent need its own notification?
Usually, yes, because a different fragrance changes the formula. Your Responsible Person will confirm how to structure notifications for a range.
Who writes the safety report?
A qualified safety assessor, commissioned by or for the Responsible Person, using data supplied by the manufacturer.
Planning an EU range? Start with our Europe hotel amenities hub or talk to us about private-label hotel toiletries.
Related service: Hotel amenities supplier for European hotels →
Tell us your idea. An account manager replies within 1 business day.
