Sectors and timing
Do cosmetics and natural health products need a passport?
Cosmetics are inside the EU ecodesign regulation, and no rule covers them yet. A natural health product follows its classification.
A cosmetic product needs no European Union (EU) digital product passport today. Cosmetics are inside the scope of the Ecodesign for Sustainable Products Regulation (ESPR). The European Commission has adopted no rule that reaches them.
Food gets a different answer, because ESPR does not reach food at all. A face balm is inside ESPR, and no rule covers it yet.
If you ignore this page, you can make two mistakes. You can buy a passport system that no rule requires. You can also treat a cosmetic like a food, and then miss the rule if the Commission writes one.
A natural health product is the harder case. The answer depends on how the destination market classifies the product.
Article 1(2) does not exclude cosmetics
ESPR creates the digital product passport. It is Regulation (EU) 2024/1781.
Article 1(2) lists the products the regulation does not cover. Cosmetics are not on that list. Neither are tobacco products, and neither are medical devices. All three stay inside ESPR scope. See ESPR exclusions for the full list.
Scope is not a duty. A product inside scope needs a passport only when a separate rule covers it.
No delegated act exists, so no cosmetic needs a passport
ESPR creates no passport duty by itself. Article 9 makes a passport a condition of market access. That condition applies only to a product group that a delegated act covers. The act names the product group and the date it applies. See what is a delegated act.
As at 14 August 2026 the Commission has adopted no delegated act for any product group. So no cosmetic product needs a passport today, and no other product group needs one either. See which products need a passport, and when.
The Commission publishes no adoption year for cosmetics
The Commission publishes an indicative timeline of the groups it plans to write rules for. That timeline names iron and steel, textiles, aluminium, tyres, furniture and information and communication technology products.
Cosmetics are not on it. So this site gives no year for a cosmetic passport, because no year is published.
Warning: a published sector year is the year the Commission expects to adopt a rule. It is not a compliance date. See how to read the timeline.
| Item | Status |
|---|---|
| ESPR, Regulation (EU) 2024/1781 | In force from 18 July 2024 |
| An ESPR delegated act for cosmetics | Not adopted. No adoption year published. |
| Cosmetics Regulation (EC) No 1223/2009 | Applies today, and it is not a passport rule |
A natural health product gets one of three classifications
Classification decides the answer. The destination market decides the classification.
| How the market classifies the product | Position under ESPR | What it needs today |
|---|---|---|
| A cosmetic product | Inside scope | No passport. No rule covers cosmetics. |
| A food | Outside scope, Article 1(2) | No passport. Food is excluded. |
| A medicinal product | Outside scope, Article 1(2) | No passport. Medicines are excluded. |
All three rows give the same answer today. They can give different answers later.
A cosmetic can get a rule, because ESPR reaches it. A food or a medicine cannot, because ESPR does not reach it at all. See food and feed are excluded and medicinal products are excluded.
Take one New Zealand ingredient, such as kanuka oil. In a face balm it is a cosmetic. In a registered medicine it is a medicinal product. In a capsule the classification depends on the market. Ask your EU importer for that classification. The ingredient does not decide the position.
Check the classification in the market you sell into
ESPR is EU law. It applies to a product placed on the EU market. So the EU classification of your product settles the question, and the New Zealand one does not.
Get the answer from the operator that places the product on the EU market. That operator is usually your EU importer. It knows how the product is registered in the EU. See who is the economic operator.
For a cosmetic there is a second party to ask. Regulation (EC) No 1223/2009 requires a person established in the Union to take responsibility for each cosmetic product. Article 13(1) of that regulation requires notification of the product before it goes on the EU market. The responsible person knows the category the product was notified under.
That regulation is not a passport rule, and it does not create one. It applies today, and it is separate work.
Do not buy a passport system for a cosmetic this year
No rule requires one, and no adoption year is published. If you buy a system now, you build it before the requirements exist.
Two sales claims are worth a check.
- A supplier may say that ESPR requires a GS1 Digital Link web address. The regulation names no such scheme. It names the ISO/IEC 15459 series in Annex III. See identifier schemes: what is verified and what is not.
- A supplier may quote a sector year as a deadline. Those years are adoption years, and the cosmetics group has no year at all.
Your packaging is a different matter. Packaging is a separate physical good in EU law. It has its own rule, Regulation (EU) 2025/40. Check that separately. See packaging.
No New Zealand guidance covers this
The Ministry of Foreign Affairs and Trade (MFAT) published one report on digital product passports, in October 2025. It gives a timeline by category. Cosmetics is not one of those categories.
A search in August 2026 found no guidance from Natural Health Products NZ. It found no guidance from four other New Zealand sector bodies either. See what New Zealand agencies have said.
Ask your EU importer how each product is classified
- Ask your EU importer how each product is classified in that market.
- Get the answer in writing, product by product.
- If the answer is cosmetic, monitor for a delegated act, which does not exist today.
- If the answer is food or medicine, ESPR does not reach the product.
- Ask the same question again for each new market you enter.
Keep the classification for each market in one place. It answers this question, and it decides which other EU rules reach the product. See first steps for a New Zealand exporter.