Many clients ask us whether the products they order already come with complete documentation. In this article, we take a closer look at the topic. We hope it helps you understand the process and clarifies who is responsible for the product.

Table of contents

Required documentation

In the European Union, according to Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products, every product placed on the market must be accompanied by appropriate documentation, which includes:

• a product description facilitating assignment to the correct documentation;
• a cosmetic safety assessment report (usually based on relevant tests, the scope of which depends on the type of product);
• details of the manufacturing process along with confirmation of compliance with GMP;
• materials supporting the claimed effects of the product (where applicable);
• information on any animal testing conducted by the manufacturer, their distributor, or suppliers (animal testing is entirely prohibited in the EU).

The product must also be notified in the CPNP, the EU portal used, among other things, for centralizing information about cosmetics and facilitating oversight of their safety.

Additionally, in accordance with the regulations, the manufacturing facility that produces cosmetics must be entered into the “register of facilities manufacturing cosmetic products.”

The concept of the Responsible Person

The Responsible Person may be either an individual or a legal entity. This is the entity responsible for ensuring that the product complies with regulations.

Typically, the Responsible Person for private label perfumes is the company placing the product on the market, i.e., the client’s company. It is possible to appoint another Responsible Person, provided they are based within the European Union.

Sometimes clients ask us whether we can assume the role of the Responsible Person. Unfortunately, at this moment we do not perform this function on behalf of clients, but we cooperate with other specialized entities that offer this service. If needed, we can act as an intermediary in communication.

Responsibility for compliance with regulations

Finally, it is worth noting that although, according to the regulations, the Responsible Person is formally accountable for product compliance, we, as the manufacturer, stand behind our products and take responsibility toward our clients. Therefore, we not only ensure full compliance and documentation but also assist in case of inspections.

Do the ordered perfumes already have complete documentation?

AromaPartners offers full private label cooperation with a very wide range of personalization options. This means that our clients can not only choose a fragrance from a list of several thousand references but also create their own. They can also freely determine the fragrance composition dosage. Full individualization of the bottle or packaging is also possible.

Every product, in order to receive Safety Reports, must undergo the appropriate tests. In the case of perfumes, these typically include dermatological tests, stability tests, and packaging compatibility tests. Such tests must evaluate the specific, individual formula in its final packaging. Additionally, in the Safety Reports, each component (whether cosmetic or packaging) must be analyzed individually. It is also worth noting that the documentation is issued for a specific Responsible Person.

Since every product we create is different, it is not possible to provide ready-made cosmetic product documentation before the production. However, it is important to remember that even though the documentation is not ready before ordering, we ensure it is prepared each time for every individual product commissioned.

As for documents related to the manufacturing facility, such as the description of manufacturing methods according to GMP or confirmation of registration in the list of cosmetic manufacturers — we of course possess these.

Does the documentation cost extra?

Documentation and testing always involve costs. We do not hide them in the product price — we list them separately each time unless the client wishes us to apply another method.

This approach ensures transparency and easier cost management for clients because documentation is generally a one-time cost (unless legal or product changes occur).

Naturally, our clients have full freedom in cooperation, so they may prepare the documentation on their own. In such cases, we provide the required certificates. However, most often we handle everything comprehensively, especially since we have negotiated very favorable pricing.

Do fragrance compositions have all the necessary certificates?

All fragrance compositions we use, both ready-made and custom-created, come with complete documentation, including, among others:

• safety data sheet;
• statement on the absence of animal testing;
• allergen list;
• IFRA certificate.

Labeling compliance with regulations

Just as important as having the proper documentation is ensuring that labeling complies with regulations. We handle this each time by providing clients with full guidelines (including the required INCI list for packaging) and reviewing artwork before production.

Summary

Documentation is prepared separately for each product, allowing full personalization and great flexibility in choosing solutions.

However, we ensure full regulatory compliance and very favorable pricing conditions for testing and documentation preparation.