Business Solutions
Subscription Box Compliance
Curated beauty boxes carry a hidden compliance load: every product and every sample inside is a cosmetic in its own right, and importing other brands' products can make the curator the Responsible Person.
A subscription box looks like one product to the customer, but to the regulation it is a collection of individual cosmetics, and each one has to stand on its own.
Every item is a product
Each cosmetic in a box, including travel and sample sizes, is a product in its own right: it needs its own Cosmetic Product Safety Report under Article 10, its own notification under Article 13, and labelling that meets Article 19. Sample sizes are not exempt, and the smaller format often raises its own labelling questions about how the mandatory information fits.
The importer and Responsible Person trap
The point that catches curators out is the Responsible Person role. A box that includes products from brands outside the UK or EU, brought in and supplied by the curator, can make the curator the importer and, under Article 4, the Responsible Person for those products, with all the Article 5 obligations that follow. We assess the box product by product, establish where the Responsible Person duty falls, and put the compliance in place so the box can ship lawfully.
Relevant services
CPSR
From £70 · 2 to 3 days
The Cosmetic Product Safety Report is the safety assessment required under Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product may be placed on the UK or EU market. Prepared and signed by a qualified safety assessor.
Learn more →Responsible Person
From £149 · per product, per year
Oxford Biosciences acts as your Responsible Person in the UK and the EU under a single quality management system, holding the regulatory obligation: PIF maintenance, SCPN and CPNP notification, labelling oversight, and cosmetovigilance.
Learn more →Labelling
From £195 · from receipt of artwork
Independent review of packaging artwork against Article 19, and of product claims against the six Common Criteria of Regulation (EU) 655/2013. Label review £195; per-claim review from £125; substantiation dossiers from £1,495.
Learn more →Frequently asked questions
What is a CPSR?
A Cosmetic Product Safety Report (CPSR) is the safety assessment required by Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product is placed on the UK or EU market. Annex I sets out two parts: Part A, the cosmetic product safety information (composition, physico-chemical and microbiological characteristics, stability, exposure and the toxicological profile of each substance), and Part B, the safety assessment, in which a qualified assessor states and reasons the conclusion on safety. It is the pivotal scientific document held within the Product Information File.
What is a Responsible Person?
Every cosmetic product placed on the EU or UK market must have a Responsible Person established within that jurisdiction. Under Articles 4 and 5 of Regulation (EC) No 1223/2009, the Responsible Person is the legal entity that holds the regulatory obligation for the product: it maintains the Product Information File, makes the CPNP or SCPN notification, oversees labelling, and handles cosmetovigilance and contact with the competent authority. It is not simply a postal address. Oxford Biosciences acts as Responsible Person in both the UK and the EU under a single quality management system.
What must appear on a cosmetic label?
Article 19 of Regulation (EC) No 1223/2009 sets out the mandatory particulars: the Responsible Person's name and address, the nominal content, the date of minimum durability or the period-after-opening (PAO) symbol, precautions for use, the batch number, the product function, and the list of ingredients in INCI nomenclature. In Great Britain the same requirements apply through the Cosmetic Products Enforcement Regulations 2013, and since 1 January 2026 the UK Responsible Person's details must appear on the label of products sold in GB. Oxford Biosciences reviews packaging artwork against these requirements for £195.