Import Cosmetics Into the EU: Requirements Step by Step

Cosmetics made in the United States, Korea, China, Turkey or anywhere else outside Europe can be sold in the EU, but only if the importer meets a set of clear obligations. This guide explains the requirements to import cosmetics into the EU: who is responsible, which documents you need, how the product must be notified and labelled, and what customs checks to expect.

The short answer

To import cosmetics into the EU, the product needs a Responsible Person established in the EU (by default the importer), a signed cosmetic product safety report and product information file, notification in the CPNP portal before it is placed on the market, compliant ingredients and labelling that includes the country of origin, and manufacture under good manufacturing practice. There is no EU licence or product registration with customs; the controls are the documentation and the Responsible Person.

Who counts as the importer?

An importer is a business established in the EU that places a product from a non-EU country on the EU market. This is the moment of first making it available, not simply the arrival at a port. Under Regulation (EC) No 1223/2009, for an imported product the importer is the Responsible Person (RP) unless it designates another EU-established person by written mandate that is accepted in writing. A non-EU brand cannot be its own RP in the EU, and it cannot simply ship to consumers and wait for the EU rules not to apply: consumer parcels sent to EU customers are subject to the same rules.

Read also EU Cosmetics Regulation 1223/2009 Explained in Plain English

What does the importer or RP have to guarantee?

• The product is safe under normal or foreseeable use.
• A cosmetic product safety report exists and the product information file is kept at the RP’s address.
• The product is notified in the CPNP before it goes on sale.
• Ingredients respect the EU annexes of banned and restricted substances.
• The label is correct and, for imports, shows the country of origin.
• The product is made under good manufacturing practice.
• Problems are handled: complaints, serious undesirable effects, corrective action and recall.

Step 1: confirm the product is a cosmetic

A cosmetic is a substance or mixture applied to the external parts of the body or to teeth and mouth mucous membranes, mainly to clean, perfume, protect, change appearance or keep in good condition. Products that claim to treat or prevent disease, such as some sunscreens or anti-dandruff products marketed with therapeutic claims in other countries, may fall outside the cosmetics regulation. Classify the product before you invest in documentation, because the same item can be a cosmetic in one country and a drug or other product in another.

Step 2: check the formula against the EU annexes

Many countries permit ingredients that the EU bans or restricts, and the EU lists of colourants, preservatives and UV filters are positive lists: only listed substances can be used. Ask the manufacturer for the full formula with concentrations, compare it with the annexes and check restrictions on fragrance allergens and microplastics. Do this before the first order, not at the customs desk. The EU also does not allow the marketing of cosmetics whose final formulation or ingredients were tested on animals to meet the regulation.

Read also Cosmetic Responsible Person (RP): Who Needs One and What They Do

Step 3: get a CPSR and build the product file

Every product needs a cosmetic product safety report (CPSR), signed by an assessor with qualifications recognised in the EU. Part A collects the safety data: formula, physical and chemical properties, microbiological quality, impurities, packaging, intended use and exposure. Part B is the assessor’s opinion. The product information file adds the product description, proof of good manufacturing practice, evidence for claims and animal testing information, and it is kept for ten years after the last batch is placed on the market, available to authorities in a language they easily understand. A safety report or “certificate” issued for another market is not a substitute.

The supporting data usually includes stability and packaging compatibility, microbiological quality and, for water-based products, a challenge test. Ask your manufacturer which of these they already have and which methods were used, so you do not repeat work.

Step 4: verify good manufacturing practice

The factory must work under good manufacturing practice, and following ISO 22716 gives a presumption of conformity. A certificate is not mandatory, but evidence is. Request a certificate or audit report, and write quality expectations into the supply contract: batch records, change notification, complaint handling and sample retention.

Step 5: notify in the CPNP

Before the product is placed on the market, the RP submits the product to the Cosmetic Products Notification Portal. The notification includes the product name and category, the RP and importer, the country of origin, the contact for poison centres, nanomaterials if present, the frame formulation and the original label. A single notification covers all EU Member States.

Read also CPNP Notification: How to Register a Cosmetic Product

Step 6: label for the EU

The label should show the name and address of the RP, the country of origin of the imported product, nominal content, the date of minimum durability or the period after opening symbol, precautions, batch number, function and the ingredient list in INCI names. Warnings must be in the language required by the Member State where the product is sold. If your factory printed the packaging for another market, plan a re-labelling step before shipping, because stickers applied in the EU by the importer are common but must be legible, indelible and cover the information correctly.

Step 7: customs and shipping

Customs is a separate process from product law. Expect a customs declaration, a tariff code, duties and import taxes as applicable, and possible checks that the product matches its paperwork. The importer named on customs documents should be consistent with the RP on the label. A freight forwarder can handle the formalities. We do not give legal advice, so ask a customs specialist about tax, duty and origin questions.

Selling online to EU consumers from outside the EU

Online sales do not create an exception. If your web shop ships to consumers in the EU, the products are being made available on the EU market, so the same Responsible Person, safety report, notification and labelling rules apply. Marketplaces increasingly ask sellers to show the Responsible Person and the CPNP details for each listing, so keep that information ready and make sure the product page matches the label.

Common mistakes

• Assuming that a foreign certificate or registration is accepted in the EU.
• Shipping first and appointing an RP afterwards.
• Not checking the formula against the EU annexes.
• Omitting the country of origin or the EU address on the label.
• Relying on the supplier to hold the product file in a place the RP cannot reach.

Frequently asked questions

Can I import cosmetics into the EU without a CPSR?

No. A signed safety report is part of the compliance file that must exist before the product is placed on the market.

Do I need to notify each EU country?

No. One CPNP notification by the Responsible Person covers all Member States.

Can the non-EU manufacturer appoint someone in the EU?

Yes. The manufacturer or importer can designate an EU-established Responsible Person by written mandate. That person must accept the role in writing and have access to the full product file.

Key takeaways

• Imported cosmetics need an EU Responsible Person, a CPSR, a product file and a CPNP notification.
• Check ingredients against EU annexes and label with the EU address and country of origin.
• Good manufacturing practice must be evidenced, even if a certificate is optional.
• Customs and product law are separate; handle both before the first shipment.