Conclusion first: US marketplace cosmetics reviews look at "two sets of documents." When selling skincare, color cosmetics, and personal care products on Amazon US, the platform often requires two types of documents: first, company registration and product listing information under the FDA system (based on the FD&C Act and MoCRA, the 2022 cosmetics regulatory amendment requiring cosmetics companies to complete facility registration and product listing); second, product safety assessment documentation. The latter has no unified mandatory name "CPSR" under US regulations, but platforms and large retailers generally require a cosmetic safety assessment report prepared in the format of Annex I of EU Regulation (EC) No 1223/2009 (CPSR, Cosmetic Product Safety Report, assessing ingredient by ingredient whether the product is safe under normal use). In one sentence: FDA registration addresses "company identity," CPSR addresses "formula safety." If either is missing, the listing may be suppressed.
Step one: distinguish the boundary between FDA registration and testing. FDA registration (multiple parts of 21 CFR, FSMA, FD&C Act, MoCRA) has a reference timeline of 10–30 working days and a reference cost range of RMB 1,000–40,000; the spread depends on product category and whether additional testing is needed. It should be noted that the FDA does not conduct pre-market approval for cosmetics; registration and listing are filing in nature; during platform review, it checks whether the registration information is consistent with the product label.
| Document | Purpose | Common rejection reasons | | --- | --- | --- | | Company facility registration information | Proves the identity of the manufacturing enterprise | Registered entity inconsistent with the label manufacturer | | Product listing information | Proves the product has been listed | Product name and ingredient list inconsistent with the actual product | | Ingredient safety documentation | Proves formula safety | Missing assessment conclusion for individual ingredients | | Label artwork | Checks ingredients and warnings | Incorrect ingredient ordering or INCI names | | Microbiological and stability reports | Supports shelf-life claims | Report batch does not match the batch on sale |
Step two: CPSR is not just "having it"; the conclusion matters. CPSR (Cosmetic Product Safety Report) is prepared according to Annex I of EU 1223/2009, with a reference timeline of 10–20 working days and a reference cost range of RMB 3,000–12,000. When platforms or retailers review it, they focus on three points: the assessor's qualifications and signature, the exposure assessment conclusion for each ingredient, and whether it clearly gives the conclusion sentence "safe under normal and reasonably foreseeable conditions of use." Reports missing the conclusion sentence are often deemed invalid.
In practice, Shuwang Testing and Certification Platform usually breaks the process into: formula and ingredient list pre-review—screening of prohibited and restricted ingredients—microbiological and stability testing—CPSR preparation—label verification. Testing is completed by partner laboratories with CNAS/CMA or equivalent qualifications; CPSR is organized and prepared by us and ultimately signed by the manufacturer or responsible person.
Step three: recommended rectification order. After being delisted, do not rush to add testing first; do three things first: check whether the label ingredient list is consistent with the formula; check whether the registered entity is consistent with the label manufacturer; check whether the CPSR conclusion sentence is complete. After fixing these three items, then add test reports;. Leave your email and an engineer will send a written evaluation within one business day.
registration subject, label ingredients and safety assessment conclusions can be reconciled with each other. Leave your email and an engineer will send a written evaluation within one business day.