Skincare supplier documents: what a pharmacy should hold

Which documents should a pharmacy hold for each skincare brand?

Nine items, split into what the supplier gives you once and what you build yourself at every delivery. The legal duties for safety sit with the Responsible Person; your duties as a distributor are to check labels, store correctly and trace batches. The file proves you did both. The certifications guide explains which labels are legal and which are voluntary; this page is the working file.

Articles refer to Regulation (EC) No 1223/2009.¹

What should the Responsible Person and safety documents look like?

Short written statements, not thick files. Ask for one letter or email per brand that names the Responsible Person and their EU address, confirms CPNP notification for each SKU on your order and confirms that a safety assessment and Product Information File exist for each.¹ Then compare the address with a pack. A mismatch between paperwork and pack is the first gap to look for, and it is enough to hold the listing until it is explained.

You will not normally see the PIF. Article 11 requires it to be readily accessible to the authorities at the address given in the notification and kept for ten years after the last batch is placed on the market.¹ Your proof is the confirmation, filed by date.

What counts as GMP and certification proof?

For GMP, an ISO 22716 certificate or a recent audit report covering skincare. Article 8 presumes good manufacturing practice when harmonised standards are followed, and ISO 22716 is that guideline for production, control, storage and shipment.¹⁵ Check the date: last year's certificate says nothing about this year's batches.

For certification, take the certificate and look the products up in the COSMOS directory.⁶ Check three things: the certifier's name, that each SKU you list is covered, and the validity date. If the brand uses the COSMOS Organic signature on one product and COSMOS Natural on another, your shelf cards must follow the product, not the brand. The COSMOS guide explains the difference.

What do you check when a delivery arrives?

The label, the batch and the dates, on one opened box per SKU. Article 6(2) makes these the distributor's checks before a product is made available.¹ We suggest a short goods-in routine:

1. Responsible Person name and address present and matching item 1.
2. Batch number on the pack and on the delivery note.
3. Date of minimum durability, or a period-after-opening symbol for products lasting more than 30 months.¹
4. Ingredient list headed "Ingredients", in the same order as the INCI you hold.
5. Language suitable for your market.
6. Precautions where the product needs them.

Photograph the first box of every SKU and file the photo as item 7. When a supplier changes a label, the next photo shows it at once.

How do the 2023/1545 allergen dates affect your stock?

They split your stock in two. Regulation (EU) 2023/1545 adds 56 fragrance allergens to the labelling list, declared individually above 0.001% in leave-on and 0.01% in rinse-off products.² Products placed on the market after 31 July 2026 must carry the extended labelling; products placed on the market before that date may stay on sale until 31 July 2028.³

In practice:

• Now: at goods-in, check that new deliveries show the extended allergen declarations where relevant.
• Through 2027: sell older packs first. Mark the shelf position of any pre-August 2026 stock.
• By July 2028: any pack without the extended labelling comes off the shelf.

The extended labelling matters at the counter too. A customer with a known allergy reads the INCI line for named allergens, so your team should know which products carry them. The sensitive-skin shelf guide has the counter scripts. For retinol products, a separate set of limits and dates applies under Regulation (EU) 2024/996; the retinol limits guide covers them.

Do you need safety data sheets or certificates of analysis?

No. REACH safety data sheet requirements exclude finished cosmetic products intended for the end user.⁴ Certificates of analysis are a manufacturer's internal batch-release document and are not part of the PIF contents listed in Article 11(2).¹ If your own quality system asks for them, request them; otherwise the INCI, the safety assessment confirmation and the batch record are the documents that answer a customer or an inspector.

How does Endless Pure handle the supplier file?

Product information is available to partners; the buyer fact sheet sets out the brand facts and terms:

• Product information: available to partners once the account is verified; partners get marketing materials and product information.
• Certification: every formula except the Eye Renewal Patches is ECOCERT COSMOS certified (Natural or Organic).
• Regulation: formulas comply with Regulation (EC) No 1223/2009.
• GMP: made in ISO 22716 certified GMP facilities in Latvia, France and North America.
• Batches: every wholesale order is a fresh batch, with production time depending on the order volume, shipped with tracking, so your delivery note and batch number arrive together.

The pharmacy hub shows the lines and trade terms.