Under EU law, a shampoo bar is a cosmetic product and must comply with the EU Cosmetics Regulation (EC) No 1223/2009. Its solid format does not create an exemption. Whether you make syndet-based shampoo bars, cold-process shampoo bars, or soap-based hair wash bars, the same core requirements apply before you can sell anywhere in the EU or Northern Ireland.

1. Appoint a Responsible Person

Every cosmetic product placed on the EU market must have a Responsible Person established within the EU. This can be the manufacturer, importer, distributor, or a third party appointed in writing. The Responsible Person ensures the product is compliant, keeps the Product Information File, and handles communication with authorities.

2. Create a Product Information File (PIF)

Before a shampoo bar can be sold, the Responsible Person must have a complete Product Information File. The PIF must include:

  • A description of the shampoo bar and its intended use
  • The full formula, including ingredient quantities
  • The manufacturing method and GMP compliance statement
  • The Cosmetic Product Safety Report
  • Evidence of the claimed effect, where applicable
  • Data on any animal testing performed

3. Cosmetic Product Safety Report (CPSR)

Every shampoo bar must have a Cosmetic Product Safety Report signed by a qualified safety assessor. The CPSR consists of two parts:

  • Part A - Cosmetic Product Safety Information: quantitative and qualitative composition, physical/chemical characteristics, microbiological quality, stability, packaging, and exposure assessment.
  • Part B - Cosmetic Product Safety Assessment: the safety assessor’s conclusion, warnings, and reasoning that the product is safe under normal and reasonably foreseeable use.

Because shampoo bars are rinse-off products applied to the scalp and hair, the assessor will consider realistic exposure, pH, potential eye irritation, and any sensitising ingredients.

4. Notify the product on the CPNP

Before placing the shampoo bar on the market, the Responsible Person must notify it via the Cosmetic Products Notification Portal (CPNP). This is a mandatory online notification, not a pre-market approval. The notification includes product details, formulation, the Responsible Person, and the relevant contact details for poison centres or regulators.

5. Manufacture to Good Manufacturing Practice

Shampoo bars must be manufactured in accordance with Good Manufacturing Practice (GMP). In practice, compliance with ISO 22716 is the recognised standard. GMP covers raw material control, batch traceability, hygiene, equipment, documentation, and recall procedures.

6. Labelling requirements

The labelling on the packaging or container of the shampoo bar must be in the official language(s) of the country where it is sold. Required information includes:

  • Name and address of the Responsible Person in the EU
  • Country of origin if the product is imported into the EU
  • Nominal content at the time of packaging, indicated by weight for a solid bar
  • Date of minimum durability or the Period After Opening (PAO) symbol if the product lasts more than 30 months
  • Batch number or reference for traceability
  • Function of the product, unless it is clear from the presentation
  • Precautions for use, including any warnings required by ingredient restrictions
  • List of ingredients using INCI names in descending order; fragrance allergens must be listed individually above the relevant thresholds for rinse-off products

For unwrapped or “naked” shampoo bars, the required information must still be clearly supplied to the consumer, typically on an attached tag, sticker, or at the point of sale in line with national guidance.

7. Ingredient restrictions and prohibited substances

Every ingredient in a shampoo bar must comply with the EU Cosmetics Regulation annexes. This includes:

  • Prohibited substances listed in Annex II
  • Restricted substances listed in Annex III, e.g. certain preservatives, surfactants, or pH adjusters
  • Permitted colourants from Annex IV
  • Permitted preservatives from Annex V
  • Permitted UV filters from Annex VI

If the shampoo bar contains nanomaterials, those ingredients must be labelled with “(nano)” and may require an additional CPNP notification.

8. Microbiological safety and stability

Shampoo bars generally have low water activity, which reduces microbial risk, but this must still be justified in the safety assessment. You should have data showing the product remains stable over its shelf life, including:

  • Stability testing under appropriate storage conditions
  • Packaging compatibility testing
  • Microbiological challenge testing or a documented justification if water activity is very low

The safety assessor will confirm whether preservatives are needed based on the formulation and its water content.

9. Claims and animal testing

Any marketing claim on the shampoo bar, such as “sulphate-free,” “vegan,” “dandruff control,” or “sustainable,” must be truthful and supported. Claims must not mislead consumers or imply the cosmetic has medicinal effects.

The EU also prohibits animal testing for cosmetic products and for ingredients intended primarily for cosmetic use. This applies regardless of where testing was carried out, subject to the current legal framework and Commission decisions.

10. Post-market obligations

Once the shampoo bar is on the market, the Responsible Person must keep the PIF for 10 years after the last batch is placed on the market. Serious undesirable effects must be reported to the competent authorities, and corrective actions such as recalls must be managed promptly.

In practice, the most important steps are completing a robust safety assessment, notifying on the CPNP, manufacturing under GMP, and ensuring the label meets national language and information requirements. Shampoo bars are subject to the same legal standard as liquid shampoos, so their solid format simply changes the testing and packaging details rather than the overall compliance process.