Shampoo bars are regulated as cosmetic products in the EU, so the main legal framework is the EU Cosmetic Products Regulation (EC) No 1223/2009. This applies whether you manufacture in the EU or import into the EU/EEA. Below are the core requirements you must meet before placing a shampoo bar on the EU market.

1. Appoint a Responsible Person

Every cosmetic product must have a Responsible Person established in the EU. This can be the manufacturer, importer, or a third party such as a regulatory consultant. The Responsible Person is legally responsible for ensuring the product complies with the Cosmetic Products Regulation and for holding the required documentation.

2. Prepare a Cosmetic Product Safety Report

Before selling, a Cosmetic Product Safety Report (CPSR) must be prepared by a qualified safety assessor. The CPSR includes:

  • The product’s quantitative and qualitative composition
  • Physical, chemical and microbiological specifications
  • Stability and packaging compatibility data
  • Traceability and manufacturing method information
  • Safety assessment of each ingredient and the final product
  • Assessment of the product’s safety for its intended use and foreseeable misuse

For a solid shampoo bar, particular attention is paid to pH, microbial quality, stability, and safe use of surfactants, preservatives, and fragrance allergens.

3. Create and Maintain the Product Information File

The Responsible Person must keep a Product Information File (PIF) for each product. The PIF contains the CPSR, a description of the manufacturing method, proof of Good Manufacturing Practice compliance, and evidence substantiating any product claims. It must be kept for 10 years after the last batch is placed on the market.

4. Follow Good Manufacturing Practice

Shampoo bars must be manufactured according to Good Manufacturing Practice (GMP). The harmonised standard is EN ISO 22716, which covers personnel, premises, equipment, raw materials, production, quality control, and documentation.

5. Notify the Product on the CPNP

Before the shampoo bar is sold, the Responsible Person must notify it on the Cosmetic Products Notification Portal (CPNP). The notification includes:

  • Product name and category
  • Responsible Person details
  • Country of first placing on the market
  • Full ingredient list, including fragrance allergens
  • Original product label and a product photograph

This must be done before the product is placed on the market.

6. Label the Product Correctly

The label on the shampoo bar itself, or on its immediate packaging, must include the following in a legible and indelible way:

  • Name and address of the EU Responsible Person
  • Nominal content by weight or volume at the time of packaging
  • Batch number or reference for traceability
  • Date of minimum durability or Period After Opening (PAO). For solid shampoo bars with a shelf life over 30 months, the open-jar PAO symbol is usually used, e.g. “12M”.
  • Function of the product unless it is obvious from the presentation
  • Ingredient list using INCI names, in descending order of weight. Fragrance allergens from Annex III must be listed individually when above 0.001% in leave-on products or 0.01% in rinse-off products.
  • Any warnings or precautions required by Annexes III-VI of the Regulation.

Because shampoo bars are often sold without outer packaging, the information may need to appear on an attached tag, sticker, or cardboard sleeve.

7. Check Ingredient Restrictions and Prohibitions

All ingredients must comply with the substance rules in the Cosmetic Products Regulation:

  • Annex II - prohibited substances
  • Annex III - restricted substances, including many preservatives and fragrance allergens
  • Annex IV - permitted colourants
  • Annex V - permitted preservatives
  • Annex VI - permitted UV filters

Particular attention should be paid to preservatives, as not all preservatives work well in anhydrous or low-water solid bars. If your product is truly water-free and not at risk of microbial growth, you may not need a preservative, but this must be justified in the safety assessment.

8. Substantiate Product Claims

Any claim made for the shampoo bar - such as “moisturising”, “sulphate-free”, “plastic-free”, “zero waste”, “biodegradable” or “natural” - must be truthful, clear, and supported by evidence. Environmental claims in the EU are under increasing scrutiny from the Green Claims Directive and national consumer authorities, so avoid vague or unsubstantiated “green” claims.

9. Packaging and Extended Producer Responsibility

If your shampoo bar uses paper, cardboard, plastic, or other packaging, you may also have obligations under EU packaging and packaging waste rules. Many EU countries require registration for Extended Producer Responsibility (EPR) and payment of packaging fees. If you claim packaging is compostable or recyclable, you must ensure those claims meet local standards.

A note on “soap” vs cosmetic shampoo bars

If your product is a true soap made by saponifying fats or oils and is marketed only for washing without any cosmetic claim, it may fall outside the full Cosmetic Products Regulation in some cases. However, if it is marketed for hair cleansing, conditioning, or any cosmetic purpose, a shampoo bar is treated as a cosmetic and must comply with the requirements above. Most commercial shampoo bars are synthetic detergent-based cosmetics, not true soap.

This is a general overview, not legal advice. Because national implementation and enforcement can vary, it is strongly recommended to work with an EU cosmetics regulatory consultant or responsible person service before launching your shampoo bar.