Why products you rinse off don’t get an exemption: CPSR is mandatory
Because shower gels and liquid soaps are products that you rinse off and are only on your skin for a short time before you wash them away, they are often considered low-risk cosmetics. As a result, many small producers think they do not have to comply with strict regulations. However, all cosmetics, whether rinsed off or left on the skin, must have a full Cosmetic Product Safety Report (CPSR) in accordance with EU Cosmetics Regulation (EC) No. 1223/2009. Regardless of whether they are water-based or contain preservatives, liquid soaps and shower gels are not exempt.
This makes sense, because despite staying on the skin for less time, rinse-off products still contain fragrances, preservatives, surfactants and allergens that can irritate the skin, cause allergic reactions or be harmful to the environment. Article 16 of the regulation states unequivocally that rinse-off products must meet all requirements. This requires manufacturers to maintain a product information file (PIF), conduct a comprehensive safety assessment and ensure that claims and labeling are accurate. The first step toward compliance for formulators and brands is the realization that shower gels and liquid soaps must meet the same rigorous tests as creams and serums.
Main components in CPSR for shower gels and liquid soaps
Preservatives: provide stability against microbial growth
Because of their water base, shower gels and liquid soaps are especially susceptible to microbial contamination. Preservatives are therefore essential and not optional. During the shelf life of the product and while the consumer uses it, the CPSR must assess the preservative system chosen and demonstrate that it effectively prevents the growth of fungi, yeasts and bacteria. To demonstrate the reliability of the system, a Preservative Efficacy Challenge Test (also called a challenge test) is usually required.
Not all preservatives are the same, so safety evaluators must consider concentration, toxicological profile and consumer sensitivity. In the CPSR, even commonly used preservatives such as phenoxyethanol and organic acid mixtures must be justified. The reviewer must also consider whether the preservative is compatible with fragrances, surfactants and other ingredients in the formulation, as interactions can reduce efficacy. Detailed testing and documentation are still required, even though requirements for preservative systems for rinse-off products are usually less stringent than those for cosmetics that remain on the skin.
Surfactants: balance between cleanliness and safety
Surfactants form the basis of shower gels and liquid soaps. While they provide the foaming, cleansing effect that customers expect, they also raise safety concerns. Many surfactants can dry out or irritate the skin, especially with repeated use. The concentration, irritation potential and overall toxicological profile of the surfactant must all be assessed by the CPSR. Because environmental compatibility is a requirement under EU regulations, surfactants are also assessed for biodegradability.
To reduce irritation, formulators often mix milder surfactants such as betaines or glucosides with primary surfactants such as sodium lauryl ether sulfate (SLES). The CPSR must prove that the chosen blend cleans well and has minimal side effects. Safety evaluators must still determine a margin of safety (MoS) for the surfactant system to protect consumers, even though the short contact time with skin in rinse-off products reduces some risks.
Allergens in rinse-off products: labeling and concentration limits
Many shower gels and liquid soaps have fragrance as a distinguishing feature, but this also introduces allergens that must be carefully managed. According to EU legislation, certain fragrance allergens must be listed on the ingredient list if their presence in rinse-off products exceeds 0.01%. Limonene, linalool and citronellol, which are often found in citrus or floral fragrances, are common allergens.
By assessing the composition of the fragrance and ensuring that labeling complies with Annex III of the regulation, the CPSR must consider allergen content. Cumulative exposure is another factor that safety assessors consider, especially if users use multiple fragranced products daily. A common compliance risk for brands is the incorrect listing of allergens. In addition to preventing legal problems, transparent labeling promotes confidence among consumers who may be sensitive to certain ingredients.
Compliance pitfalls
Underestimation of preservative requirements
A common mistake made by manufacturers is the assumption that rinse-off products do not need strong preservatives. Although these products are easy to clean, their high water content makes them susceptible to microbial growth. Because shower water provides the perfect environment for microbial growth, contamination can occur during both storage and use if appropriate preservatives are not used. Inadequate justification of preservatives is often cited by safety reviewers as a compliance problem in CPSRs.
Ignoring irritation from surfactants and biodegradability
Ignoring the potential irritation caused by surfactants is another mistake. Rinse-off products do not last long on the skin, but they can remove the skin’s natural oils and leave a dry or irritated feeling. The effectiveness and safety of the surfactant system must be demonstrated by the CPSR. In addition, surfactants must be biodegradable to comply with environmental regulations. The safety report may have gaps if no biodegradability data are provided or if the references are outdated.
Missing updated labeling requirements for fragrance allergens
A common reason for non-compliance is fragrance allergies. The list of allergens that must be listed on cosmetic labels is regularly updated by the EU. A regulatory red flag is when ingredient labels are not updated with the latest requirements. Manufacturers must identify specific allergens above thresholds; it is not enough to just list “perfume. PIFs must include supporting documentation from fragrance suppliers and CPSRs must accurately reflect allergen information.
Establish a robust CPSR and PIF for rinse-off products
Structuring safety reporting (Part A and Part B).
Safety information on the product is collected in Part A of the CPSR and the findings of the safety assessor are presented in Part B. Quantitative formulations, toxicological profiles of ingredients, details of exposure scenarios and the results of stability and microbiological tests are all required in Part A for shower gels and liquid soaps. Part B must then state that the product is safe for consumer use under normal and predictable conditions, based on the reviewer’s professional judgment.
Because consumers often use multiple laundry products per day, evaluators also consider cumulative exposure when evaluating rinse-off products. To ensure that even repeated use is safe, safe exposure levels must be calculated for different scenarios. Manufacturers demonstrate professionalism and compliance by properly structuring the CPSR.
Required tests: microbiological, stability and toxicology of ingredients
Testing is the backbone of the CPSR. Microbiological tests ensure that preservatives keep the product free of contamination. Stability tests verify that the product maintains its safety, efficacy and appearance over time and under different storage conditions. Toxicological assessment of each ingredient ensures concentrations remain within safe limits.
For rinse-off products, these tests are not optional. Regulatory agencies expect documented results to be included in the PIF. Insufficient or missing test data is one of the most common reasons for noncompliance. Manufacturers who invest in proper testing not only meet regulatory requirements, but also gain confidence in the quality and longevity of their products.
Documentation of responsible person, GMP and product labeling
The responsible person, the legal entity responsible for marketing the product, must be listed in the PIF along with the CPSR. In addition, it must include proof of Good Manufacturing Practices (GMP), which demonstrates that production meets accepted standards of quality and hygiene. Another important element is labeling, which must clearly include the ingredient list, batch codes, shelf life, warnings and allergen statements.
Small or new brands often underestimate these factors, despite the fact that they are crucial for compliance. Manufacturers demonstrate that their products meet the administrative and organizational requirements of EU cosmetics legislation and safety regulations by carefully documenting the responsible person, GMP and labeling.
FAQ: Quick answers about shower gel safety and compliance
V1. Are shower gels considered safe cosmetics?
Yes, but “low risk” does not mean they are exempt. Under EU law, they still need a full CPSR and PIF.
V2. Is a preservative required for all shower gels?
Yes. They must contain powerful preservatives because they are water-based. Challenge tests show the effectiveness of the preservative.
V3. What rules apply to the labeling of liquid soap regarding allergens?
Allergens in fragrances must be listed on the label of rinse-off products if their concentration exceeds 0.01%.
V4. What tests are required to comply with CPSR?
Ingredients should be tested for stability, microbiological properties and toxicological effects.
V5. Can a small craft brand market products without submitting paperwork?
No. Before products are marketed, all brands, regardless of size, must have CPSR, PIF and compliant labeling.
Conclusion & how YouWish can help
Shower gels and liquid soaps may seem easier to make than cosmetics that stay on the skin, but they are still subject to strict EU cosmetics regulations. Every ingredient, from preservatives and surfactants to fragrances and allergens, must be carefully considered, tested and properly labeled. Even rinse-off products must fully comply with EU Regulation 1223/2009, which means that safety reports, microbiological testing and proper documentation are essential in order to market your creations with confidence.
At YouWish, we are here to help make this journey smoother. In addition to our wide selection of fragrance oils, essential oils and soap bases, we offer knowledge and resources that help you understand what it takes to create safe and compliant formulations. Whether you’re experimenting at home or expanding your soap business, we’ll help you create products that delight customers and meet EU standards.
Are you ready to get started? Browse our collection of ingredients and supplies for shower gels and liquid soaps at YouWish and turn your ideas into professional-quality, standards-compliant cosmetics.
