Importing Cosmetics into the EU: The Essential Guide for New Importers (And the Pitfalls to Avoid)
Understanding the Real Requirements Behind Importing Cosmetics into the EU
The popularity of Korean skincare and innovative beauty products from outside the EU has surged in recent years. The EU, however, enforces some of the strictest cosmetic regulations globally, defined in the EU Cosmetics Regulation (EC) No 1223/2009. This guide explains the essential compliance steps and common pitfalls faced by new importers entering the EU market.
The Responsible Person (RP): Your Most Crucial Compliance Requirement
A cosmetic product cannot be notified on the CPNP without an appointed EU Responsible Person (RP). Notifications can only be submitted through the Cosmetic Product Notification Portal (CPNP). If your business requires support, Annel provides full regulatory representation via our EU Responsible Person service.
- A legitimate product has both an RP and a valid CPNP notification
- Without an RP, the product cannot legally enter the EU market
Key safety concerns:
- Supplier refusing to reveal the RP is a major red flag
- Non-compliant products risk detention at customs
The Hidden Risks of Importing Unregistered Cosmetics
EU border authorities regularly detain cosmetic shipments lacking proper documentation. Examples of seized non-compliant cosmetics appear frequently in the EU Safety Gate (RAPEX).
- Shipments blocked at customs
- Daily storage fees
- Weeks-long delays
- Potential destruction of goods
What Documentation Is Required for EU Cosmetic Compliance?
To enter the EU market, every cosmetic must have a complete Product Information File (PIF). Ingredient compliance must align with the official EU CosIng ingredients database.
- CPSR – Cosmetic Product Safety Report
- Stability & compatibility testing
- GMP compliance
- Ingredient specifications
- Testing (microbiological, challenge test)
- EU label compliance
Further information can be found on the Cosmetic Regulatory Blog.
Questions You MUST Ask Your Supplier Before Ordering
- Is the product registered through the Cosmetic Product Notification Portal (CPNP)?
- Who is the Responsible Person?
- What is the CPNP number?
- Can the RP issue a Product Mandate?
Working with New or Unregistered Cosmetic Brands
- Manufacturer document collection
- Safety assessments & testing
- PIF preparation
- CPNP notification via the official portal
- Regulatory representation via our Responsible Person service
Compliance Checklist for Manufacturers, Importers and Distributors
Product Audit
- Check compliance with Regulation (EC) 1223/2009
Reformulation
- Review prohibited & restricted substances using CosIng
Documentation
- Prepare a complete PIF including CPSR, testing, and labelling review
Supply Chain Actions
- Confirm GMP manufacturing compliance
Risk Management
- Monitor alerts in the EU Safety Gate (RAPEX)
FAQ
- Do I need an EU Responsible Person to import cosmetics?
Yes — an RP is required to submit notifications through the Cosmetic Product Notification Portal (CPNP). - Can I import a brand that is not registered?
Yes — but only after full compliance (PIF, testing, CPNP notification) is completed via a qualified RP such as our Responsible Person service.
Conclusion
Importing cosmetics into the EU can be profitable and sustainable when approached with proper compliance. Verifying documentation, ensuring CPNP registration, and working with a qualified Responsible Person significantly reduces risks. For support with regulatory compliance, reach out via our Contact page.
