Why there is nothing on sale yet
Every cosmetic in the EU needs a named Responsible Person and a CPNP notification. We are asking for both, per product, in writing — and until they arrive, the shop stays shut.
Routinae sells some of the products written about here, so read this the way you would read any shop’s opinion of its own shelves. Where we think a cheaper product does the same job we say so, and where the evidence is thin we say that too. Our buying standard is published so you can check the argument against it.
This shop has been visible for longer than it has been open. That is deliberate, it is slightly embarrassing, and the reason is two acronyms that almost nobody outside the industry has heard of.
Here is the whole explanation, because a delay you can see and cannot understand is worse than one you can.
The two things every cosmetic in the EU needs
A Responsible Person. Under the EU Cosmetics Regulation, every cosmetic placed on the market must have a named company or individual, at a real address inside the EU, who holds that product’s safety documentation and answers for it. Not a PO box. Not “the brand, in Seoul”. A findable European entity with a name on it.
A CPNP notification. Before a product is made available, it has to be notified to the Cosmetic Products Notification Portal, the European Commission’s central database. That notification is what lets a regulator, or a poison centre at two in the morning, find out what is actually in the bottle.
Neither of these is paperwork for its own sake. Together they are the machinery that makes a product recall possible. Without them there is no mechanism — just a bottle, an importer who may or may not answer the phone, and you.
Why this is our problem in particular
The Regulation distinguishes between a distributor and a Responsible Person, and the gap between them is the entire reason this shop is not yet trading.
Buying from a supplier established in the EU makes us a distributor. That carries real obligations — we have to check that labelling is present and correct, that dates are in order, that we are not passing on something we have reason to believe is non-compliant — but they are obligations we can meet.
If no Responsible Person exists in the chain for a product we sell, we become the Responsible Person. That means we would owe, per product, a Product Information File, a Cosmetic Product Safety Report signed off by a qualified assessor, and the CPNP notification itself. For a catalogue of this size that is not a hurdle, it is a different business.
Almost every risk in a shop like this is recoverable. You misprice something, you lose money and fix the price. A supplier disappoints you, you find another. That one is not recoverable, which is why it is the only thing we have allowed to hold up the opening.
What we ask suppliers, and what a good answer looks like
One question, per product, in writing:
For each product we list, can you provide the CPNP notification reference and the name and address of the EU Responsible Person?
There are three kinds of reply.
- A per-product CPNP reference and a named Responsible Person with an address. This is the answer. It is also rarer than you would expect.
- “All our products are CPNP registered.” Written once across a homepage, this is not an answer to the question that was asked. It may well be true. We ask for one specific product’s reference as a test, and how that goes is informative.
- No, or silence. Then we do not list their products. Not as a punishment — most B2B distributors hold the paperwork perfectly well and simply are not used to being asked for it — but because “probably fine” is not a foundation for a catalogue.
Two things we have learned doing this. The Responsible Person is specific to the importer, not to the brand, so you cannot borrow one you found on another retailer’s site and assume it covers the stock you are being sold. And a UK address is not an EU address, which sounds obvious and is nonetheless a mistake we have seen published by working European retailers.
Why we cannot simply inspect the box
The obvious shortcut is to check the pack. It does not work, and the reason is worth knowing whoever you buy from.
Counterfeit operations have become good enough that they replicate barcodes. If the barcode can be copied, so can the batch code, the safety symbols and the printing. A pack that looks right is evidence that somebody wanted it to look right. Documentation from the company that imported it is a different kind of claim, because it names somebody who can be held to it.
Where we actually are
Collecting it. Some suppliers have answered well, some have answered partially, and some conversations are still open. We are not going to pretend that is finished, and we are not going to open with a mixed catalogue where some products have the evidence and others are there because they were popular.
So the shop opens when the file is complete, product by product. In the meantime the routine guidance is free and does not require anything to be in stock, and the standard we are buying against is published so you can see what we are waiting for.
What this costs us, stated plainly
Every week closed is a week of no revenue, no reviews, and no reason for anyone to remember we exist. There is a version of this business that opened months ago on the reasonable assumption that products sold widely across Europe are probably compliant.
That assumption is usually correct. It is also exactly the assumption that puts a banned fragrance allergen or an unnotified product in somebody’s bathroom, and the whole argument of this shop is that we do the checking so you do not have to. A shop that skipped it would have nothing left to sell but adjectives.