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The legislative amendment, which will take effect on September 1, 2025, is European Commission Regulation No. 2025/877 of May 12, 2025, which amends legislation on the use of prohibited substances in cosmetic products. These prohibited substances in Annex II include:

Trimethylbenzoyl Diphenylphosphine Oxide (TPO)

We would like to inform all customers that our products sold and distributed through the BAFISHOP sales network since June 1, 2025, no longer contain TPO.

FAQ – Documentation, certification and legislation relating to cosmetic products and professional equipment

In this section, you will find answers to the most frequently asked questions regarding documentation for cosmetic products, professional nail care products and technical equipment for beauty and nail salons.

⚠️An important distinction to make first: consumer, professional and business owner

When assessing what information or documents a customer is entitled to request, it is important to distinguish between their status and the type of product. A consumer is a natural person who makes a purchase outside the scope of their business or professional activities. An entrepreneur / professional user is a person who purchases or uses a product in connection with their business or professional activities, such as a nail technician, beautician or salon owner. However, the mere fact that someone is a professional user of a cosmetic product does not automatically mean that they are entitled to access the product’s internal regulatory or manufacturing documentation, such as the PIF or CPSR.

1. What is the CPNP and do I need a CPNP code?

CPNP (Cosmetic Products Notification Portal) is a European electronic portal through which legally required product information is notified to the European Commission prior to the placing of a cosmetic product on the EU market. Responsible persons and distributors also have access to the system to the extent corresponding to their authorisation.

⚠️Does the seller have to provide the customer with a CPNP number or ‘CPNP code’? NO, generally not.

The CPNP is not a certificate intended for the customer, and the CPNP reference number is not information that, under the Cosmetics Regulation, must be stated on the product packaging or routinely provided to the end user.

2. What is an SDS – a safety data sheet?

SDS (Safety Data Sheet) is a safety data sheet used primarily for chemical substances and mixtures under the European REACH chemical legislation. It contains, for example, information on hazardous properties, safe handling, storage, first aid, fire safety measures, disposal and transport. For normal professional use of a finished cosmetic product, an SDS is not automatically a document that a salon must obtain from the supplier for every product.

⚠️Does every cosmetic product need to have an SDS? NO.

⚠️Do I need an SDS as a nail technician or beauty salon? NO.

3. What is a ‘certificate’ for a cosmetic product?

The term certificate is used very broadly in practice and can refer to various documents. However, in the case of cosmetic products, there is no single universal ‘EU certificate’ that must automatically be issued for every gel polish, gel or other cosmetic product and handed over to the customer.

⚠️Must the seller issue or provide the customer with a ‘certificate’? NO, unless specific legislation for a particular product requires such a document.

The customer cannot therefore automatically demand a vague ‘cosmetics certificate’ as a condition for the lawful use of a properly labelled cosmetic product. If a customer requests a specific document, we always recommend clarifying which document they are requesting and for what purpose they need it.

4. What is an EU Declaration of Conformity?

⚠️Do I need a Declaration of Conformity for gel polish or gel? NO.

When it comes to cosmetic products, it is essential to distinguish between cosmetics and electrical and electronic equipment.

When is an EU Declaration of Conformity used?

It is primarily relevant for products subject to European harmonised regulations, typically certain electrical and electronic equipment. For a specific piece of equipment, it always depends on which European regulations apply to it.

⚠️Does the seller have to provide the customer with an EU Declaration of Conformity? NO.

The method of making the document available is governed by the specific legal provisions applicable to the product in question. The Declaration of Conformity is primarily a document proving compliance with the relevant EU requirements and must be available, in particular, for inspection by market surveillance authorities.

5. PIF and CPSR.

⚠️Is the seller obliged to provide the PIF or CPSR to the customer? NO.

Neither the PIF nor the complete CPSR are documents intended for routine provision to end customers or beauty salons. The PIF contains, amongst other things, technical, regulatory and commercially sensitive information. The responsible person is obliged to ensure its availability to the relevant supervisory authorities in accordance with the requirements of European legislation. Even a professional user of a cosmetic product is not automatically entitled to a copy of the PIF or CPSR simply by virtue of purchasing the product.

6. As a customer, do I have the right to know the composition of a cosmetic product? YES.

In accordance with the legislation, a cosmetic product must bear a list of ingredients (INCI), usually on the product packaging. Furthermore, European legislation sets out a specific scope of information that the responsible person must make available to the public. However, this does not imply that the customer has the right to obtain the complete formulation or the entire PIF.

7. Is a professional nail technician an ‘end user’? YES, they may be.

A beauty salon or a nail technician who uses the product whilst providing a service to a customer is therefore not automatically a distributor of the cosmetic product. The situation is different if the salon resells the products or otherwise places them on the market. In such a case, it may also act as a distributor and is subject to further obligations.

8. Is a product labelled ‘Professional Use Only’ safe and legal?

The label ‘For professional use only’ means that the product is intended for use by a professionally trained or qualified person, or that such a restriction stems from the relevant regulatory requirements. It does not mean that lower safety standards apply to professional cosmetics.

9. Must cosmetics bear the CE mark? NO.

Cosmetic products are not normally marked with the CE mark. The CE mark is used only for product categories covered by the relevant EU harmonisation regulations. The absence of the CE mark on a cosmetic product is therefore not a shortcoming.

10. How can I tell if a cosmetic product has been lawfully placed on the EU market?

⚠️The customer does not need to verify the product’s internal regulatory documentation. The packaging of a cosmetic product must bear the information required by law. For products imported from countries outside the EU, the country of origin must also be stated.

11. Must the information on a cosmetic product be in Czech?

Information for which Czech legislation requires the use of the Czech language must be provided in Czech when the product is supplied to the end user in the Czech Republic. The list of ingredients is provided in accordance with the prescribed INCI cosmetic nomenclature and is not translated into Czech in the usual way.

12. Must a cosmetic product bear an expiry date?

This depends on the product’s shelf life. For cosmetic products with a minimum shelf life of 30 months or less, the date of minimum durability must be stated.

13. Must every cosmetic product have a batch number?

A cosmetic product must bear a production batch number or other information enabling its identification. This information is particularly important for product traceability and for dealing with any complaints, safety issues or the withdrawal of a specific batch from the market.

14. Who is responsible for the safety of a cosmetic product?

The so-called Responsible Person, established in the EU, is primarily responsible for compliance with the key requirements of cosmetics legislation. Their name and address must be stated on the cosmetic product. The distributor has their own obligations, in particular to verify the prescribed information on the labelling, compliance with language requirements and, where applicable, the best-before date, and to ensure that storage and transport do not jeopardise the product’s compliance with legal requirements.

15. Is a cosmetics retailer automatically the Responsible Person? NO.

A retailer or distributor is not automatically the responsible person. A distributor is an entity in the supply chain that is neither the manufacturer nor the importer and places the cosmetic product on the market.

16. What if a beauty salon also sells products to customers?

If a beauty salon merely uses a cosmetic product whilst providing a service, it generally acts as a professional end-user. However, if it also resells cosmetic products to customers, it becomes part of the distribution chain in this aspect of its business and is subject to the relevant obligations of a distributor.

17. Can I request the exact formulation of a gel polish or other cosmetic product? NO.

Neither an ordinary customer nor a professional user has an automatic right to the complete formulation of the product. The INCI list of ingredients and other information required by law are intended primarily for the customer. The complete quantitative composition forms part of the product’s technical documentation and may constitute a trade secret of the manufacturer or the responsible person.

18. Can a regulatory authority request documentation that a customer is not entitled to receive? YES.

It is essential to distinguish between documentation intended for the customer and documentation intended for the competent authorities. The responsible person, importer or distributor must, within the scope of their legal obligations, cooperate with the competent supervisory authorities and, upon their justified request, submit the information and documentation necessary to demonstrate the product’s compliance.

19. So, as a customer, what documents do I actually need?

For the normal purchase and use of a properly labelled cosmetic product, the customer does not usually need: the CPNP number, the PIF, the complete CPSR or the complete formulation. An SDS is not automatically required for a finished cosmetic product intended for the end user. Above all, the customer must have access to the information necessary for the correct and safe use of the product, its identification and any further information required by law for that type of product.

20. What is the difference between documentation for cosmetics and documentation for electrical appliances?

It is important not to confuse these two categories.

Cosmetic products – such as gel polishes, UV gels, base coats or top coats – are primarily subject to Regulation (EC) No 1223/2009 on cosmetic products.

Electrical and electronic equipment – such as UV/LED lamps, electric nail files or dust extractors – is subject to different European legislation.

For these products, the following are particularly relevant depending on the specific product: the CE marking, the EU declaration of conformity, technical documentation, instructions for use and safety information. Therefore, the same documents cannot be required for a cosmetic product and an electrical appliance.

⚠️Warning

The information provided in this section is of a general nature. Obligations may vary depending on the specific type of product, its composition, method of use, origin, method of placing on the market and the status of individual entities in the supply chain. The currently applicable legislation of the European Union and the Czech Republic relating to the specific product is always decisive.