RECORDREFERENCE OUTLINE

Cosmetic Market Compliance File (US and EU)

One compliance file for a cosmetic sold in the US and the EU: the responsible person in each market, the EU safety report and US safety substantiation, GMP evidence, US facility registration and product listing, EU notification, the EU product information file, and adverse event reporting under both regimes with their different clocks.

What a template is not

A template is a document baseline to adapt inside your own quality system. SPEQ does not approve, validate, or take responsibility for what you issue from it, and using one is not evidence of compliance.

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HOW TO FILL THIS IN
How to Place a Cosmetic on the US and EU Markets, step by step →
REGULATIONS MAPPED
MoCRA 2022Regulation (EC) No 1223/2009ISO 22716
DOCUMENT TYPE
Record
LAST UPDATED
October 2026
PURPOSE

A single file that shows a cosmetic meets the responsible-person obligations of both the US Modernization of Cosmetics Regulation Act of 2022 and the EU Cosmetics Regulation. The two regimes ask for similar things in different forms — safety evidence, GMP, registration or notification, and adverse event reporting — so one file, kept current, avoids two diverging records of the same product.

What's Inside

✓The responsible person in each market and the basis for the EU designation
✓The EU safety report, the safety assessor’s qualification and the US safety substantiation
✓GMP evidence against ISO 22716 for each facility
✓US facility registration and product listing, and EU notification, with renewal dates
✓The contents of the EU product information file and how long it is kept
✓Adverse event reporting under both regimes, with their different deadlines

How to Use It

1Start one file per product, or per formulation family where the safety report covers the family.
2Confirm the responsible person in each market before any other entry.
3Build the EU safety report first and record how it also supports US substantiation.
4Diarise US registration renewals every two years and listing updates every year.
5Route all complaints through one intake that applies both reporting clocks, and review the safety case when new information arrives.
DOCUMENT CONTENTS

The full section structure of this template — every section and sub-section, so you can use it as a baseline for your own site document.

—Document Control
› Document Information› Approval Signatures› Revision History› Distribution List
1Product and Responsible Persons
2Safety
3Manufacturing
4Registration, Listing and Notification
5EU Product Information File
6Adverse Event Handling
AAppendix A — Approval
REGULATORY CONTEXT

Under MoCRA, as described on FDA’s MoCRA page, the responsible person reports serious adverse events within 15 business days, lists products and updates listings annually, and keeps safety substantiation records, while facilities register and renew every two years; FDA has records-access and mandatory-recall authority, and is required to issue GMP regulations. Regulation (EC) No 1223/2009 requires a responsible person (Article 4), GMP with a presumption of conformity from harmonised standards (Article 8), a safety assessment and report (Article 10), a product information file kept for ten years (Article 11), notification (Article 13) and reporting of serious undesirable effects without delay (Article 23). The file structure is SPEQ practitioner synthesis.

MAPPED STANDARDS
MoCRA 2022Regulation (EC) No 1223/2009ISO 22716
Browse the standards catalog →