Critical Risk
Missing CPNP notification — illegal to sell
Every cosmetic product must be notified on the EU Cosmetics Notification Portal (CPNP) before being placed on the EU market. Without this, the product is illegal regardless of ingredient compliance. Chinese factories cannot submit CPNP — only the EU Responsible Person can.
Critical Risk
Prohibited ingredients (1,628 banned substances)
Annex II of the EU Cosmetics Regulation lists 1,628 prohibited substances. Common Chinese cosmetic ingredient failures include mercury in skin-lightening creams, high concentration retinoic acid, and certain preservatives like chloroform. Chinese factories often formulate for domestic CN standards, not EU ones.
High Risk
No Product Information File (PIF)
Each cosmetic product requires a Product Information File containing: product description, safety assessment (by qualified person), manufacturing method, proof of claims, and microbiological data. Most Chinese suppliers cannot provide PIF-compliant documentation without EU-side coordination.
High Risk
Electrical beauty devices — RED and LVD compliance
IPL hair removal devices, LED therapy masks, EMS face devices, and sonic cleansers must comply with the Low Voltage Directive (LVD 2014/35/EU) and the Radio Equipment Directive (RED 2014/53/EU) for wireless-enabled devices. CE declarations are routinely incorrect for these products from China.
Medium Risk
Labelling — INCI names, language, and PAO
EU cosmetic labelling requires: INCI ingredient list, Period After Opening symbol, batch reference, Responsible Person address, country of origin, and precautionary statements in the local market language. Chinese factory labels almost never meet EU requirements directly.
Medium Risk
Claims substantiation — "natural", "organic", "dermatologist tested"
EU Cosmetics Regulation Article 20 requires that all product claims be truthful, evidenced, fair, and non-misleading. "Natural" and "organic" have no legally defined threshold in the EU — but unsubstantiated claims can trigger market surveillance action under GPSR and national consumer protection law.
