What are the EU regulations for selling shampoo bars?

If you plan to sell shampoo bars in the European Union, the most important legal framework is Regulation (EC) No 1223/2009, the EU Cosmetics Regulation. Shampoo bars are treated as cosmetic products because they are intended to cleanse the hair and scalp. This means they must meet the same safety, labelling, notification and documentation requirements as liquid shampoo or any other cosmetic.

1. Shampoo bars are cosmetic products

Under EU law, a cosmetic product is any substance or mixture intended to be placed in contact with the external parts of the human body - including the hair and scalp - mainly to clean, perfume, protect or keep them in good condition. A shampoo bar falls squarely within this definition. This classification matters because it triggers the full set of obligations under the Cosmetics Regulation.

2. Appoint a Responsible Person

Every cosmetic product sold in the EU must have a Responsible Person. This is a legal entity established in the EU who takes responsibility for the product’s compliance. The Responsible Person may be:

• the EU-based manufacturer
• the EU-based importer, if the shampoo bars are manufactured outside the EU
• a company appointed by the manufacturer or importer via a written mandate

The Responsible Person must keep the Product Information File at an EU address and ensure the product is safe and compliant before it is placed on the market.

3. Compile a Product Information File and safety assessment

Before selling shampoo bars, you must have a Product Information File (PIF) for each product. The PIF must include:

• a clear description of the product
• the Cosmetic Product Safety Report (CPSR), signed by a qualified safety assessor
• a description of the manufacturing method and a statement of Good Manufacturing Practice compliance
• evidence of the claimed effect, where relevant
• data on any animal testing, where applicable

The CPSR is a key document. It must be prepared by a person with suitable qualifications in pharmacy, toxicology, dermatology or a related field. The safety assessor evaluates the ingredients, the final formulation, stability, microbiological quality, packaging and realistic use conditions. For solid shampoo bars, particular attention is often paid to water activity and whether a preservative is needed to prevent microbial growth.

4. Follow Good Manufacturing Practice

Shampoo bars must be manufactured according to Good Manufacturing Practice (GMP). The EU standard is EN ISO 22716, which covers the production, control, storage and shipment of cosmetic products. You do not necessarily need a GMP certificate, but you must be able to demonstrate that your production process follows GMP principles.

5. Notify the product on the CPNP

Before placing a shampoo bar on the EU market, the Responsible Person must notify it through the Cosmetic Products Notification Portal (CPNP). This is a free online system run by the European Commission. The notification includes details such as the product category, formula, responsible person and label artwork. Notification is mandatory for every cosmetic product, and it must be completed before the product is sold or distributed.

6. Meet EU labelling rules

The label on a shampoo bar must comply with Article 19 of the Cosmetics Regulation. Required information includes:

• the name and address of the Responsible Person
• the nominal content - usually weight for a solid bar
• the batch number for traceability
• the product’s function, unless it is obvious from the presentation
• special precautions for use, if any
• the ingredient list in INCI format, in descending order of concentration

For durability, you must include either a “best before” date or, if the product lasts more than 30 months, a period-after-opening (PAO) symbol, usually an open jar with a number of months. The label must be in the official language or languages of the EU country where the product is sold.

7. Respect ingredient restrictions and annexes

Only cosmetic-grade ingredients may be used, and every ingredient must comply with the Cosmetics Regulation’s annexes:

• Annex II lists prohibited substances
• Annex III lists restricted substances and allowed concentrations or conditions
• Annex IV lists permitted colourants
• Annex V lists permitted preservatives
• Annex VI lists permitted UV filters

If your shampoo bar contains fragrance allergens above certain thresholds, those allergen names must appear in the ingredient list. Essential oils and botanical extracts are common in shampoo bars, so check whether any individual fragrance components need to be declared on the label.

8. Be careful with claims

Claims about your shampoo bar must comply with the EU’s common criteria for cosmetic claims under Regulation (EU) No 655/2013. Claims must be truthful, evidence-based and not misleading. Avoid making medicinal claims, such as “treats psoriasis”, “cures dandruff” or “prevents hair loss”, unless the product is authorised as a medicinal product - otherwise it may be considered an illegal medicinal claim.

Environmental claims such as “plastic-free”, “zero waste”, “biodegradable” or “vegan” must also be accurate and substantiated. The EU is tightening green claims rules, so keep evidence for any environmental or sustainability statement you make.

9. Packaging, waste and environmental obligations

Although the Cosmetics Regulation is the main product rule, shampoo bar sellers must also think about packaging and waste law. The EU Packaging and Packaging Waste Directive and national extended producer responsibility schemes may apply. Depending on the country, you may need to register with a national packaging register or pay fees for the packaging you place on the market. For example, Germany has the LUCID packaging register and France has CITEO-style obligations.

If your shampoo bar is sold as “plastic-free” but has a label, wrapper or sticker, those items can still be considered packaging and may be subject to national packaging rules.

10. Additional country-specific rules

EU rules create a harmonised baseline, but individual Member States can have additional requirements. These may include language requirements, specific recycling symbols, national packaging registers, or extra environmental labelling rules. If you sell online to different EU countries, you should check the national rules in each target market or work with a compliance partner.

In short, selling shampoo bars in the EU requires a Responsible Person, a safety assessment and PIF, GMP-compliant manufacturing, CPNP notification, correct labelling, compliant ingredients and careful claims. The rules are demanding, but they apply to small businesses and large brands alike. This guide is a general overview, not legal advice - for your specific formulation and sales model, consider consulting a cosmetic regulatory expert.