A skincare factory developed a moisturizing cream for the AliExpress EU site and listed it after self-commissioning routine microbiological and heavy metal testing. After the product had been sold on the French and Spanish sites for about three months, the platform's compliance spot check required the company to provide CPSR (Cosmetic Product Safety Report, signed by a qualified assessor, proving that the product is safe for human health under normal use) and CPNP (Cosmetic Products Notification Portal, on which notification must be completed before the product is placed on the market) notification records.
The CPSR provided by the company was signed by a non-compliant assessor, and the ingredient list was inconsistent with the actual formula version; the responsible person information in the CPNP notification differed from the EU responsible person on the packaging label. The platform determined that the document chain was not closed, and multiple SKUs were delisted. The company also found that the original testing items did not cover the fragrance allergens in the formula and needed reassessment.
Freeze the current formula version and establish a version control table in which the formula, CPSR, CPNP notification, and label are consistent Have a qualified assessor reissue the CPSR, supplement fragrance allergen and preservative challenge test data, and verify the information required by Annex I Correct the responsible person information in the CPNP notification, update the packaging label accordingly, and resubmit for platform review
After rectification, the three SKUs resumed sales. The CPSR cycle for a single product is about 10–20 working days, with a reference cost range of RMB 3,000–12,000. The company subsequently incorporated the version control table into its new product launch process.
Cosmetics compliance is not a single report, but a consistency issue among the four-piece set of formula, CPSR, CPNP, and label Once the formula is changed, the CPSR and notification must be updated simultaneously, and for cross-border e-commerce multi-site sales, EU responsible person information especially must be unified