One Formula, 30 SKUs: Do Cosmetic Shades and Sizes Need Separate CPSRs?
Understand why pack sizes, shades, scents and reformulations can change the scope and price of cosmetic PIF and CPSR work.
This guide summarises EU or GB requirements as understood in October 2026. For product-specific decisions, the appointed Responsible Person and qualified specialists must review the actual dossier.
A SKU is a commercial identifier, not a universal safety-assessment unit
Brands often sell one underlying cosmetic formula in different sizes or across multiple shades and fragrance options. Those may create 10, 50 or 100 retail SKUs without 100 wholly independent base formulations. Regulatory and professional charging models do not always match this structure. The question is whether the evidence and risk assessment legitimately cover a variation, not simply whether its stock-keeping code is different.
Bottle sizes and formulation changes are different issues
A 30 ml and 50 ml pack containing the same formulation may share substantial safety evidence, subject to packaging compatibility, usage and other relevant factors. A different fragrance system, pigment set or preservative can change toxicological considerations and may require new or expanded safety work. An assessor needs sufficient information to decide. A brand should not promise itself that every shade or scent is automatically covered by one report.
What can be reused in a family
Some ingredients, manufacturing methods, packaging evidence or toxicological references may overlap across a product family. An appropriately structured product database links each SKU to its base formula, variations, components and document versions. This can reduce avoidable duplicate requests and make it easier for a qualified assessor to identify genuinely common evidence. It must not conceal differences that materially affect product safety.
The questions to ask before accepting a quote
Ask providers whether their price is per SKU, product name, underlying formulation, variation or safety report. Clarify the allowable types and number of variations, notification work, PIF scope, artwork checks and ongoing update fees. Have them review a sample family: for instance eight foundation shades, three fragrance options and two pack sizes. That is far more meaningful than comparing a bare 'from £199' headline.
Portfolio-friendly operations matter as much as discounts
Where the same manufacturer supplies many products, centralised evidence requests and shared product records can reduce administrative work. Build a master list with unique formula identifiers and keep a change log. Varanos can help organise that inventory and coordinate specialist review; it cannot override an assessor's conclusion about whether separate assessments or PIF information are required.
Official sources
Regulatory guidance evolves. Follow the links below to check for subsequent updates.
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