Multi-market guide

Selling cosmetics on marketplaces.

Amazon, Etsy, Shopify, TikTok Shop: the channel changes nothing about the law and everything about enforcement. Regulators knock rarely; marketplaces check constantly, and a listing suppressed for missing Responsible Person details is the modern compliance penalty.

Cosmetic products prepared for online marketplace listings with compliance records

Reviewed by Cassandra Maddocks, chemist & biochemist · last reviewed 26 July 2026

Do marketplace sellers need the same compliance as everyone else?

Yes: every duty is channel-agnostic. A cosmetic sold into the EU through Amazon or a personal Shopify store needs the same Responsible Person, safety report, Product Information File and notification as one sold in a pharmacy. No marketplace's own review substitutes for any of it.

The converse is the trap: a marketplace that does not check your safety report at listing time has not waived it. The obligations under Regulation (EC) No 1223/2009 attach to placing the product on the market, however you do it.

What does Amazon ask cosmetics sellers for?

In the EU and UK, Amazon actively requests Responsible Person and manufacturer details and can suppress or suspend listings that cannot provide them. A valid Responsible Person with the details on file is effectively a condition of keeping a cosmetics listing live.

This makes the marketplace the fastest enforcer in the chain: a cantonal lab or Trading Standards officer may never contact you, but Amazon's compliance sweep will. Appointing an EU RP and UK RP before listing, not after the flag, is the difference between a smooth launch and a revenue gap.

Can I ask my supplier for proof of CPNP notification?

Ask, yes; compel, usually not. The notification belongs to the Responsible Person, and no provision of the cosmetics regulation forces a wholesaler to hand a reseller the record. What a distributor must do is verify that the product carries an RP address, the required label particulars and, on request from authorities, identify its supplier.

The practical answer for a reseller is to buy from suppliers who share compliance details willingly, because you carry distributor duties of your own: under the regulation a distributor must check the labelling before selling and must not supply a product it has reason to think is non-compliant. If a wholesaler cannot or will not show that an RP exists for the product, treat that as your answer. If you are rebranding rather than reselling, the duties change completely; see the private label guide. The roles are set out in Regulation (EC) No 1223/2009, and what the notification actually contains is in our CPNP guide.

What did the GPSR change for online sellers?

Since 13 December 2024, the EU's General Product Safety Regulation requires every product sold into the EU, including through online marketplaces, to have an EU-established responsible economic operator. It ended the era of non-EU sellers shipping into the EU with no EU presence at all.

For cosmetics the fix is the appointment you already need: the Responsible Person under Regulation 1223/2009 fills the role. The text is at GPSR (EU) 2023/988; how it interlocks with the RP role is covered in our EU RP guide.

Article 16 of the GPSR on EUR-Lex with the EU economic operator requirement highlighted
Article 16(1) of the General Product Safety Regulation (EU) 2023/988 on EUR-Lex, with the requirement for an EU-established economic operator highlighted. Captured 26 July 2026. View the official text.

What about selling into the US through marketplaces?

MoCRA applies in full: facility registration, product listing, safety substantiation, a US contact on the label and adverse-event reporting do not depend on the sales channel. A marketplace storefront is "marketing in the United States" from the first sale.

The one relief is the small-business exemption for firms under the sales threshold, which is common among marketplace-first brands but voided by eye-area and similar products. Above the line, the product listing duty runs per product, per the usual timings.

The marketplace wants an FDA certificate my exemption says I do not need. What now?

This is common on TikTok Shop and similar US category checks: the platform asks for proof of FDA registration, but a MoCRA-exempt small business has nothing to show, because the FDA does not issue exemption certificates. The fix is a documentation package: a signed self-declaration of exemption with the statutory basis, plus the compliance records you do hold.

Platforms want evidence someone stands behind the product, not the impossible certificate their form names. A letter citing the small-business exemption in the Modernization of Cosmetics Regulation Act, with your sales basis and product categories, alongside labels and safety substantiation, resolves most category reviews. Whether you actually qualify, and which products void the exemption, is covered in our small-business exemption guide. If you are over the threshold, registering properly is faster than arguing: request a US compliance quote.

The FDA registration and listing page noting that FDA does not issue certificates for registrations or listings
The FDA's Registration and Listing page, with the note that FDA does not issue certificates for registrations or listings highlighted. Captured 26 July 2026. View the official text.

My listing was flagged or suspended. What now?

Identify exactly what the marketplace is asking for (usually Responsible Person or manufacturer details for the EU or UK), then close the underlying gap rather than contesting the flag. Marketplaces reinstate listings when the compliance record exists; they rarely argue about it.

This is a service pattern we handle regularly: tell us which marketplace, which market and what it requested, and we stand up the missing structure and supply the details in the format the marketplace expects. Start with the contact page for a flagged listing, or request a quote to set up properly before you list.

Listing soon, or listing suspended?

We set up the Responsible Person, safety report and notifications marketplaces check for, and supply the details in the format they expect when a listing is flagged.