Cosmetics, skincare, hair care, electrical beauty devices — China is the world's largest manufacturer. But EU Cosmetics Regulation 1223/2009 imposes strict obligations that most Chinese factories cannot fulfil without importer guidance.
EU cosmetics law places full legal responsibility on the EU importer — not the Chinese manufacturer. The factory cannot register your products for you.
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.
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.
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.
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.
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.
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.
| Regulation | Scope | Key requirement | Status |
|---|---|---|---|
| EU Cosmetics Regulation 1223/2009 | All cosmetic products | CPNP notification, PIF, Responsible Person, labelling | In force |
| Annex II — Prohibited substances | All cosmetic ingredients | 1,628 banned substances — pre-market ingredient screening required | In force |
| Annex III — Restricted substances | Certain cosmetic ingredients | Max concentrations for H₂O₂, fluoride, colorants etc. | In force |
| LVD 2014/35/EU | Electrical beauty devices | Low voltage electrical safety — CE marking required | In force |
| RED 2014/53/EU | Wireless beauty devices | Radio equipment compliance — bluetooth, WiFi, app-connected | In force |
| GPSR — General Product Safety Regulation | All consumer beauty products | Economic operator traceability, digital product passports (2027) | From Dec 2024 |
| REACH SVHC | Beauty packaging and accessories | SVHC disclosure above 0.1% — packaging materials | In force |
| PPWR — Packaging Regulation | All cosmetic packaging | Recyclability, recycled content targets, packaging minimisation | Phased 2025–2030 |
Monthly supplier assessments, Cosmetics Regulation compliance checks, prohibited ingredient scanning, and Safety Gate monitoring — all focused on your beauty niche.
