Bring a cosmetics, dermocosmetics or aesthetic-medicine brand to the Polish and EU market — or grow it — with a legal partner who understands the sector.
The cosmetics industry operates in one of the most heavily regulated segments of the consumer market — the EU Cosmetics Regulation (EC) No 1223/2009 places obligations on the Responsible Person regarding product safety, documentation and notification through the EU’s CPNP portal, while a separate Regulation (EU) No 655/2013 sets common criteria for justifying cosmetic claims in advertising and on packaging. On top of that come consumer law, customer data protection, distribution and online sales, and protection of brand and formulas.
We support cosmetics, dermocosmetics and aesthetic-medicine brands at every stage — from entering the Polish and EU market, through ongoing product and marketing compliance, to commercial contracts and disputes. The practice is led by Oliwia Koper, who advises international clients in the cosmetics sector day to day, and Kinga Miller, Partner and certified Approved Compliance Expert.
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Support in meeting the Responsible Person’s obligations: notifying the product through the EU’s CPNP portal before it is placed on the market, keeping a complete Product Information File, and labelling in line with the regulation’s requirements.
Reviewing cosmetic claims against the common criteria of Regulation (EU) No 655/2013 (lawful compliance, truthfulness, evidential support, fairness), and reviewing ad campaigns, packaging copy, influencer materials and promotions for consumer-law compliance and protection against misleading advertising.
Distribution, agency and import agreements, selective-distribution structures, marketplace and own-store online sales terms, compliance with the Omnibus Directive (price-cut disclosures, consumer reviews), online-store terms and conditions, and handling complaints and returns.
Registering and protecting the brand’s and product lines’ trademarks, protecting packaging designs, enforcing rights against counterfeits and grey-market goods, and licensing and private-label agreements.
Drafting and negotiating private-label / contract manufacturing agreements, raw-material and packaging supply agreements, agreements with laboratories and testing providers, and corporate support for group entities.
GDPR in loyalty programmes, online sales and skin-diagnosis / product-matching tools (including AI-based solutions), data transfers within international groups, and data security incident handling.
For dermocosmetics and aesthetic-medicine brands: support with product classification (cosmetic vs. medical device) and the accompanying regulatory obligations, and reviewing marketing communications from clinics and brands in this space.
Placing a cosmetic product on the EU market requires CPNP notification, complete safety documentation (CPSR, PIF), and lawful marketing claims. Here is the practical, step-by-step path we guide our clients through.
A team that knows the cosmetics industry from the angle of law, regulation and marketing communication — from product compliance to day-to-day legal support.
Kinga Miller
Partner · Attorney · Approved Compliance Expert
Kinga has 15 years of experience negotiating agreements, including copyright and industrial-property matters, and handling litigation. As a certified Approved Compliance Expert she advises brands on building compliance systems and safe marketing communication.
Marta Solarska-Kaleńczuk
Partner · Chief Operating Officer · Data Protection Officer
Marta specializes in personal data protection, new technologies, consumer law, and compliance. As a Data Protection Officer she advises brands on GDPR in online sales and loyalty programs, distribution agreements, and aligning marketing communications with competition and consumer law.
Oliwia Koper
Associate · Attorney
Oliwia specializes in life-sciences legal advisory, intellectual property law and compliance. She advises international businesses day to day, in particular in the cosmetics and FinTech sectors, combining medical-law experience with regulatory matters and IP protection.
Any such claim must satisfy the criteria of Regulation (EC) 655/2013 and be backed by supporting evidence in the product's PIF.
Using the word without an evidentiary basis risks the claim being deemed misleading — we always assess specific wording individually.
Registration with the competent state district sanitary inspector must be filed within 30 days of starting operations.
We help complete this formality and identify the authority competent for a given location.
Responsibility rests with the Responsible Person named at CPNP notification.
That may be the manufacturer, the importer, or a distributor who has contractually taken on the role.
Market surveillance is carried out by the Chief Sanitary Inspectorate (GIS), including cosmetovigilance — monitoring and reporting serious undesirable effects, both to GIS and via the CPNP system.
Medicinal products and medical devices remain within the remit of URPL; in borderline cases we determine the competent authority individually.
The rules and any fees depend on the current CPNP portal requirements and the scope of the notification.
We verify these individually when preparing the notification for a given product.
The distinction depends on the product's claimed purpose and mechanism of action — a cosmetic acts superficially, for care and appearance, whereas a medical device is associated with diagnosing, preventing, or treating a condition.
Borderline products require individual legal classification before choosing a notification path.
Legal position: July 2026. The above is general information about our practice areas, not legal advice in an individual matter.
Let’s talk about how we can protect and accelerate your business — from product compliance to day-to-day legal support.
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