What the PIF! What Regulators Are Seeing on the Ground

Every year, more cosmetic brands enter the market. Most of them are small. Many of them are founder led. A lot of them are built on good intentions, creativity, and a strong Instagram presence.

And far too many of them are launched without a proper understanding of cosmetic regulation.

Recent enforcement action in France has made that painfully clear. Inspectors reviewed nearly 150 cosmetic businesses, most of them very small and relatively new to the sector. Their focus was the Product Information File, the document that must exist before a cosmetic product is placed on the market and which proves that the product is safe for consumers.

What they found was not subtle.

Only around one in five businesses could produce a complete or near complete PIF. Some had no PIF at all. Most had files that were incomplete, inconsistent, out of date, or created after the products were already being sold. Which, from a regulatory perspective, is the wrong way round.

The PIF is not paperwork for paperwork’s sake. Under EU cosmetic law, it is the backbone of product safety. It contains formulation details, manufacturing information, evidence to support claims, and most importantly the Cosmetic Product Safety Report. If that report is missing, ignored, or misunderstood, the product should not be on the market.

Yet inspectors repeatedly found safety reports that were absent, incomplete, or simply unread. In one case, a product was being sold even though the safety assessor had issued a negative opinion. In others, brands claimed safety data was available on request, as if that were an acceptable substitute for actually including it in the file.

Claims were another recurring problem. Words like regenerating, hydrating, or suitable for sensitive skin were being used without any real evidence. Some justifications amounted to references from commercial websites, Wikipedia, or informal testing on the business owner and their friends. That is not substantiation. It is wishful thinking.

Even when safety assessors had set clear usage restrictions, some brands ignored them. Products intended for adult use only were marketed to families. Instructions allowed more frequent use than assessed as safe. Allergies, sensitivities, and real world consumer risk were treated as an afterthought.

Regulators responded proportionately. Some businesses received warnings and guidance. Others faced formal injunctions, enforcement action, or criminal procedures. In the most serious cases, authorities restricted access to websites and social media to stop further sales.

The point here is not to scare small brands out of the market. It is to underline a simple truth. Cosmetics regulation is not optional, and it is not something you sort later.

If you are responsible for placing a cosmetic product on the market, you are responsible for consumer safety. A proper PIF is not red tape. It is the evidence that you have done the work, understood the risks, and taken your role seriously.

At Taylored Consultancy, we work with brands at all stages, including those who wish they had asked these questions earlier. Getting it right before launch is always cheaper, calmer, and far less painful than explaining it to a regulator after the fact.

Compliance does not kill creativity. But ignoring it can kill a brand.