Importing Cosmetics into France: Safety Reports and Notification
Introduzione
France is one of the most attractive beauty markets in Europe, and it is also one of the most closely watched. The country is home to some of the world’s best-known cosmetics groups, a dense cluster of laboratories and formulators, and a consumer base that reads ingredient lists carefully. For overseas brands and cross-border sellers, particularly those sourcing skincare, makeup, nail, hair and personal care products from China, France is a natural gateway into the European Union. It is also a market where weak paperwork shows up quickly.
Unlike many categories, cosmetics do not need a pre-market approval or a CE mark to enter the EU. What they need is a paper trail that exists before the first unit is sold: a Persona responsabile established in the EU, a Cosmetic Product Safety Report (CPSR) signed by a qualified assessor, a Informazioni sul prodotto File (PIF) kept ready for inspection, and a notification in the Cosmetic Products Notification Portal (CPNP). None of these are customs forms, yet they decide whether a container can be sold, whether a marketplace listing survives, and whether a French inspector leaves a warehouse satisfied.
Freight forwarders see the cost of getting this wrong more often than anyone. Pallets are held while the importer hunts for a missing document, labels are re-done at a bonded warehouse at the last minute, and launch dates slip by weeks. This guide explains how safety reports and notification work in practice, what the French authorities look for, which rule changes landed in 2026, and how to line up the regulatory file with the shipment itself. It reflects developments up to mid-November 2026.
Why France Deserves Special Attention
The EU Cosmetics Regulation applies in the same way in all 27 member states, but enforcement is national. In France, market surveillance for cosmetics now sits mainly with the DGCCRF, the consumer protection and fraud control directorate, following a reorganisation that moved cosmetics tasks away from the health products agency ANSM towards the DGCCRF and the food and environmental safety agency Anses from the start of 2024. Since 1 March 2025, export certificates for cosmetics are also issued by the DGCCRF. The agency runs annual inspection campaigns, collects samples that are analysed in a joint laboratory shared with French customs, and does not announce its visits.
Its published campaign results explain why importers should take this seriously. A survey from 2018 covered 1,836 establishments and nearly 700 samples and found anomalies in 40.5 percent of the establishments visited, including prohibited substances, labelling errors, weak traceability and breaches of the lingua francese rule. The headline number is old, but the categories have barely changed. Because the EU has no pre-market approval for cosmetics, French inspectors rely on in-market controls: they review PIFs, check products physically, and send samples to the laboratory. If the file cannot be produced quickly, the importer is already on the back foot.
The Legal Framework in Plain Language
The backbone of the system is Regulation (EC) No 1223/2009, which applies directly in France without any national transposition. It replaced the old cosmetics directive and organises compliance around one idea: a named company in the EU is accountable for each product, and that company must be able to prove safety on demand. Because the rules are written as obligations on the Responsible Person rather than on the factory, a supplier’s own test report or a “CE certificate” from a trading company does not satisfy them.
The table below maps the main obligations to the articles most often cited in inspections and customs queries.
| Obbligo | Articolo di regolamento | Cosa significa in pratica |
| Persona responsabile | Articolo 4 | An EU-established legal or natural person is designated for every product placed on the market. |
| buone pratiche di fabbricazione | Articolo 8 | Products are made under GMP; compliance with the harmonised standard ISO 22716 gives a presumption of conformity. |
| Valutazione della sicurezza | Articolo 10, Allegato I | A CPSR is completed before market placement by a suitably qualified safety assessor. |
| File informativo sul prodotto | Articolo 11 | A PIF is kept for ten years after the last batch is placed on the market and made available to authorities. |
| Test sugli animali | Articolo 18 | Products or ingredients tested on animals to meet the Regulation cannot be placed on the market. |
| Etichettatura | Articolo 19 | Mandatory information appears on the pack, in the language required by the member state. |
| Sinistri | Articolo 20 | Claims must be truthful and supported by evidence. |
| Nanomateriali | Articolo 16 | Additional notification applies to nanomaterials not otherwise covered. |
| Notifica CPNP | Articolo 13 | Product data is submitted to the Commission portal before first sale. |
| Gravi effetti indesiderati | Articolo 23 | The Responsible Person reports serious undesirable effects to the competent authority. |
Two practical points follow from this structure. First, the regulation is product-based, so every SKU needs its own safety logic and its own notification, although shade ranges that share a frame formulation can often be grouped. Second, responsibility cannot be pushed upstream by contract alone. Whatever the supply agreement says, the authority will address the company named on the label.
The Responsible Person: Who Carries the Liability
Article 4 states that only products for which a legal or natural person is designated within the EU can be placed on the market. The Responsible Person ensures compliance with the regulation, keeps the PIF, completes the CPNP notification before commercial sale, cooperates with market surveillance authorities and poison centres, takes corrective action if a product is not compliant, and reports serious undesirable effects. It is the single point of accountability, and for imported products the role is rarely a formality.
When the importer is the Responsible Person
For an imported cosmetic, the importer is the Responsible Person by default. A French or EU company that brings goods in from China under its own name therefore inherits the full set of duties, even if it has never seen the formula. Many importers discover this only when an inspector asks for the CPSR and the factory turns out to hold nothing more than a Chinese-language test summary.
The importer may instead designate another EU-established person by written mandate, provided that person accepts the role in writing. The mandate should be filed in the PIF so it can be shown to authorities alongside the safety report.
Appointing a third-party Responsible Person
Chinese brands that sell directly to French consumers without an EU entity normally appoint a specialist Responsible Person. The name and EU address of that company then appears on the label, and it becomes the contact for authorities, so the choice matters. Before signing, check that the company has qualified regulatory staff, professional liability insurance and a workable process for handling complaints and recalls. Also agree what happens if the relationship ends, because the PIF must remain accessible for ten years after the last batch regardless of who the brand uses next.
One caution comes up repeatedly in sourcing circles: some suppliers claim to be “CPNP compliant” without any notification having been made. Ask for a copy of the notification confirmation and the Responsible Person’s details, and confirm they match the label artwork. It is also worth remembering that a DDP shipping arrangement does not replace a Responsible Person, and that the United Kingdom runs a separate notification system with its own UK-based Responsible Person, so a CPNP entry does not cover Great Britain.
The Cosmetic Product Safety Report
Article 10 requires a safety assessment of the finished product before it is placed on the market. The result is documented in the CPSR, which Annex I divides into two parts. Part A gathers the safety information; Part B contains the assessor’s reasoned conclusion.
| CPSR part | Contenuti |
| Part A: safety information | Quantitative and qualitative composition; physical and chemical characteristics and stability; microbiological quality; impurities, traces and packaging information; normal and reasonably foreseeable use; exposure; toxicological profile of each substance; undesirable effects and serious undesirable effects; other relevant product information. |
| Part B: safety assessment | Assessment conclusion; labelled warnings and instructions for use; reasoning behind the conclusion; credentials of the assessor, including name, address, proof of qualification, date and signature. |
What the assessor needs from your factory
A credible assessment starts with the full formula in percentages, a specification sheet and safety data sheet for every raw material, certificates of analysis, stability and compatibility tests with the actual packaging, preservative efficacy (challenge) results, microbiological data and information on traces of heavy metals or other impurities. The assessor also needs the intended users, the site of application, the amount and frequency of use, and any warnings the product will carry.
The sticking point is often confidentiality. Factories in Guangdong and Zhejiang are reluctant to disclose exact percentages to a brand owner who could move production elsewhere. A workable solution is to let the factory send formula data directly to the assessor under a non-disclosure agreement, while the brand receives the signed CPSR and the Responsible Person receives the full file.
Who can sign Part B
Under Article 10(2), the assessor must hold a diploma in pharmacy, toxicology, medicine or a similar discipline. French practice relies on a 2015 ministerial order that clarifies which qualifications are accepted as equivalent. A report signed by a general consultant without the relevant qualification can be rejected on inspection, however polished it looks.
When the report needs to be updated
The CPSR is a living document. A change of raw material supplier, a new fragrance, new packaging, a revised opinion from the Scientific Committee on Consumer Safety, an amendment to the annexes, or a pattern of undesirable effects can all trigger a review. Importers who treat it as a one-off purchase end up with files that no longer match what is actually on the pallet.
Il file informativo del prodotto
The PIF, described in Article 11, is the evidence binder behind the product. It contains a description that allows the file to be linked to the product, the CPSR, a description of the manufacturing method with a statement on GMP, proof of the claimed effect where the nature of the product justifies it, and data on any animal testing carried out by the manufacturer, its agents or suppliers. The Responsible Person keeps it at the address stated on the label and makes it available to the authority on request, in electronic or other form, for ten years after the last batch is placed on the market.
| PIF element | What an inspector expects | Punto debole tipico |
| Descrizione del prodotto | Clear link between the file and the labelled product, including variants | File refers to a development code, not the market name |
| CPSR | Signed, dated, matching the current formula | Report predates a formula or packaging change |
| Manufacturing method and GMP | Short method description and a GMP statement, ideally with ISO 22716 evidence | Statement from a trading company rather than the factory |
| Proof of effect | Test or study supporting each claim | Marketing claim added after the file was built |
| Animal testing data | Statement covering manufacturer, agents and suppliers | Silence on ingredient suppliers |
On language, the ANSM has indicated that PIF documents held in France are preferably in French, while English is acceptable. The label, by contrast, has no such flexibility. In practice, a bilingual folder with the CPSR summary and the GMP statement in French saves time when an inspector arrives with little notice.
CPNP Notification Step by Step
Article 13 requires the Responsible Person to notify each product through the CPNP before placing it on the market. The portal is operated by the European Commission, notification is free, and once a product is notified there is no need for a further national notification elsewhere in the EU. The person completing it creates an EU Login account and then selects the Responsible Person profile; a separate delegate profile exists for nanomaterial data.
| Data submitted | Dettagli |
| Categoria e nome | Product category and the name or names under which it is sold. |
| Persona responsabile | Name and address, and the address where the PIF is available. |
| Paese di origine | Required for imported products, together with the member state of first placement. |
| Persona di contatto | A named individual who can be reached in case of need. |
| Nanomateriali e sostanze CMR | Presence of nanomaterials, and identification of CMR substances of categories 1A or 1B where applicable. |
| Formulazione del frame | A formulation framework allowing poison centres to give prompt advice. |
| Etichettatura | Original label and, where reasonably legible, a photograph of the packaging. |
The order of operations is where most mistakes happen. Notification should follow the completed CPSR, not precede it, because the label and the frame formulation need to be final. A product with the wrong Responsible Person address on the pack or a formula that changes after notification forces an update and, in some cases, a new safety review.
Products containing nanomaterials that are not otherwise regulated carry an extra layer. Under Article 16, the Responsible Person notifies them separately, and the word “nano” in brackets must follow the ingredient on the label. France adds its own annual declaration to the R-Nano register for companies that manufacture, import or distribute such products. The European Parliament’s October 2026 position on the Omnibus VI package would keep the nanomaterial pre-market notification while dropping the six-month advance period, but that text is not yet law.
Finally, treat notification as something you can verify. The competent authorities can see the entry; you should be able to produce the confirmation and the CPNP reference whenever a retailer, marketplace or customs broker asks for it.
French Labelling and Language Rules
Article 19 lists what must be on the pack, and French law adds the language rule. The Toubon law of 1994 requires that all information on the labels of cosmetics sold in France is in French. A product labelled only in English is non-compliant in France even when the INCI list is perfectly complete. Over-labelling at origin or in a bonded warehouse is common and accepted, provided the sticker is durable and does not cover mandatory information.
| Elemento etichetta | Requisito | Trappola comune |
| Persona responsabile | Name and address in the EU; country of origin for imports | Chinese factory address only |
| Contenuto nominale | Weight or volume at the time of packaging | Missing on small cartons |
| La durata | Minimum durability date, or period-after-opening symbol where durability exceeds 30 months | Both omitted |
| Precauzioni | Warnings from Annexes III to VI and any specific precautions | Translated loosely |
| Numero di lotto | Allows identification of the batch | Printed only on the outer carton |
| Funzione | Stated unless clear from the presentation | Left out on multi-use products |
| Lista degli ingredienti | INCI names in descending order, with “nano” where applicable | Unconverted Chinese or trade names |
| Informazioni sul riciclaggio | French sorting and Triman information under national packaging rules | Not designed into the artwork |
Fragrance allergens deserve a separate warning. Regulation (EU) 2023/1545 extended the list of fragrance allergens that must be named individually on the label. The new requirements apply to products newly placed on the market from 31 July 2026, and to all products on the market from 31 July 2028. Perfumes, scented skincare and anything with a fragrance component are affected, and the PIF, CPNP entry and CPSR need to reflect the updated information.
Claims are the other frequent finding. The common criteria in Regulation (EU) No 655/2013 require legal compliance, truthfulness, evidential support, honesty, fairness and support for informed decisions. DGCCRF campaigns have repeatedly covered products marketed as natural or organic, and wording such as hypoallergenic, dermatologically tested or vegan needs a file behind it.
Online sellers face a related issue. Inspectors have flagged websites that show an ingredient list that does not match the product actually shipped. The Parliament’s Omnibus VI position would go further and require distance-sales offers to display the Responsible Person’s name and address, the country of origin, nominal content, precautions, function and ingredient list, applying twelve months after entry into force. It is a proposal today, but sensible sellers are building those fields into their product pages already.
Packaging is moving too. The core provisions of the EU Packaging and Packaging Waste Regulation apply from 12 August 2026 and sit alongside French extended producer responsibility, including Citeo registration, so importers should ask their suppliers for packaging material data before artwork is finalised.
What Has Changed in 2026: A Regulatory Calendar
The last twelve months have been unusually busy for anyone moving cosmetics into the EU. The table collects the developments that most directly touch importers and forwarders.
| Data | Mercato | Chi è interessato |
| 1 settembre 2025 | TPO restriction in force under the amended annexes; products containing it, such as some gel nail products, must be reformulated | Nail and gel manufacturers |
| 1 Luglio 2026 | Interim €3 customs duty per item category on B2C parcels valued up to €150, running to July 2028; import VAT rules unchanged | Direct-to-consumer sellers |
| 31 Luglio 2026 | Expanded fragrance allergen labelling applies to newly placed products; all products by 31 July 2028 | Fragrance and scented products |
| Agosto 12 2026 | Core provisions of the Packaging and Packaging Waste Regulation start to apply | All packaged goods |
| 22 ottobre 2026 | Parliament adopts first-reading position on Omnibus VI; Council position pending and no entry-into-force date confirmed | Everyone, mainly CMR and online sellers |
Omnibus VI is the item to watch. The Parliament’s text would shorten the transition periods for products affected by new CMR bans to 6 months for placing on the market and 12 months for making available when no derogation is requested, and to 3 and 9 months when a derogation is refused on safety grounds. Longer periods of 24 and 36 months would apply for certain category 1A and 1B substances where an alternative exists, but only if an up-to-date CPSR is available at all times. These periods are not running yet, and they depend on the final regulation.
The practical response is neither panic nor delay. Importers should screen formulas against CMR classifications, keep the CPSR current, and avoid committing to large production runs of formulas that rely on borderline substances. For stock already on the water, the safest approach is to check the status of every listed ingredient with the Responsible Person before the vessel sails.
Moving Compliant Cosmetics from China to France
Regulatory compliance and logistics run as two chains that meet at the French port. Customs clearance in France is digital, handled through the national DELTA system, and the importer needs an EORI number. Clean shipments typically clear in one to three days, while a documentary or physical control can add one to two weeks. A cosmetic container with an unreadable label or an unexplained ingredient is exactly the kind of cargo that gets pulled aside.
Classification and duties
Cosmetics fall mainly under Chapter 33 of the tariff, covering perfumes, beauty and skincare preparations, hair products, oral hygiene and other toilet preparations. Many lines carry zero or low duty, but the rate should be checked in the EU TARIC database for each product, and import VAT at the French standard rate applies on top. Classification has taken on extra importance since July 2026, because the €3 duty for low-value B2C parcels is charged per tariff line. A parcel containing a lipstick and a shampoo carries two lines and therefore €6, not €3.
Dangerous goods in cosmetic cargo
Many cosmetics are dangerous goods in transport terms. Alcohol-based perfumes, nail polish and removers are flammable liquids, and aerosols such as hairspray and dry shampoo fall under their own classification. By sea, these require a proper dangerous goods declaration, correct packing and marking, and a consolidator that accepts them if the cargo moves as LCL. By air, the restrictions are tighter still. Safety data sheets must match the formula in the PIF, since a mismatch between the two is an easy way to lose days at origin.
Choosing the transport mode
| Moda | Tempo di transito tipico | Più adatto per | Nota di conformità |
| FCL ocean to Le Havre or Marseille-Fos | About 30 to 40 days port to port, plus clearance | Established brands and large replenishment orders | Single consignee; simpler dangerous goods control |
| oceano LCL | Circa 35-50 giorni, incluso il consolidamento. | Ordini più piccoli o misti | Needs a consolidator that accepts cosmetics and dangerous goods |
| Trasporto aereo | Circa 5-10 giorni porta a porta | Launch stock and urgent restocks | Strict limits on flammables and aerosols |
| Pacchi espressi | Circa 5 a 12 giorni | Ordini diretti al consumatore | Per-item data and the €3 duty apply |
The transit times above are planning figures and move with port congestion and carrier schedules. Heat is a further factor for summer sailings. Container interiors can get very hot, and emulsions, natural oils and some fragrances do not tolerate it well. The stability section of the CPSR should cover foreseeable storage and transport conditions; if it does not, the shipment plan should avoid peak heat or use protective measures.
| funzionalità di | Perché è importante |
| Fattura commerciale e lista di imballaggio | Declared values, product descriptions and quantities must match labels and notification entries. |
| HS code worksheet | Supports classification and, for parcels, the per-line €3 duty. |
| Schede di dati di sicurezza | Needed for dangerous goods acceptance and for risk assessment at origin. |
| CPNP confirmation and Responsible Person mandate | Not always requested at the border, but regularly requested by customs, marketplaces and the DGCCRF. |
| Summary of the CPSR conclusion | Shows that a qualified assessor has signed off the exact formula being shipped. |
| French label artwork or over-label proof | Confirms mandatory information is in French before goods are released for sale. |
| ISO 22716 certificate of the factory | Supports the GMP statement in the PIF. |
| EORI number and customs broker authorisation | Required to lodge the declaration in France. |
How Topway Shipping Supports Cosmetics Importers
Dal 2010, la Spedizione Topway, headquartered in Shenzhen, China, has been a professional provider of cross-border e-commerce logistics solutions. The founding team has more than 15 years of experience in international logistics and customs clearance, with a strong focus on China–U.S. transportation. Its services span the entire logistics chain, including first-leg transportation, overseas warehousing, customs clearance and last-mile delivery, and it offers flexible full-container-load and less-than-container-load ocean freight from China to major ports worldwide.
For cosmetics importers into France, that experience is most useful in the weeks before the cargo leaves Shenzhen. A forwarder that understands customs documentation can compare the commercial invoice, the HS codes, the safety data sheets and the label artwork against the compliance file, and flag mismatches while there is still time to fix them at the factory. Topway Shipping can also help decide between FCL and LCL, screen the cargo for dangerous goods, and plan consolidation so that flammable and non-flammable items are handled correctly. For sellers shipping parcels directly to French consumers, the same attention to product data helps with the per-line duty introduced in July 2026.
To be clear about boundaries, a freight partner does not replace the Responsible Person or the safety assessor. The CPSR must be signed by a qualified person, and the notification must be made by the Responsible Person. What Topway Shipping contributes is coordination, so the physical shipment and the paperwork tell the same story at the port. Importers who bring the forwarder into the conversation before labels are printed usually avoid the most expensive surprise of all, which is re-labelling a full container after it arrives. Once goods are cleared, overseas warehousing and last-mile delivery give brands a way to hold stock near their customers and keep fulfilment predictable.
Errori comuni e come evitarli
| Errore | Probabile conseguenza | Prevenzione |
| Treating a supplier’s test report as a CPSR | File rejected on inspection; sales stopped | Commission an EU-qualified assessor before production |
| Etichette solo in inglese | Non-compliance with French language law; re-labelling | Prepare French artwork or durable over-labels in advance |
| Notifying before the label is final | Mismatch between notification and pack | Lock artwork and formula, then notify |
| No clear Responsible Person | No lawful basis for sale in the EU | Appoint one by written mandate before shipping |
| Ignoring dangerous goods status | Booking rejected or cargo held at origin | Share SDS with the forwarder at quotation stage |
| Not updating files after changes | CPSR and PIF no longer match the product | Set a review trigger for formula, supplier and packaging changes |
Behind most of these problems is a sequencing issue. Regulatory work, packaging work and freight booking are often handled by three different people who talk to each other late. Putting them on one timeline, with one shared document folder, removes most of the friction.
Una cronologia realistica
The schedule below is a planning guide for a new product with a cooperative factory. Durations vary with laboratory capacity and how quickly the factory returns data, so treat them as ranges rather than promises.
| Stage | Durata tipica | Dipendenza |
| Collect formula and raw material documents | 2 a 4 settimane | Factory willingness to share data |
| Stability, challenge and compatibility testing | 4 a 12 settimane | Laboratory availability; can run in parallel |
| CPSR by qualified assessor | 2 to 4 weeks after data is complete | Full and accurate dossier |
| Responsible Person mandate and PIF assembly | 1 a 2 settimane | Signed CPSR and GMP statement |
| French label design and approval | 1 a 3 settimane | Final INCI list and warnings |
| Notifica CPNP | 1 a 3 giorni | Final label and formulation frame |
| Controlli di produzione e pre-spedizione | 3 a 6 settimane | Order volume and factory schedule |
| Ocean freight and French clearance | 5 a 8 settimane | Port conditions and customs controls |
Many of these stages can overlap. Label design and testing, for instance, usually run side by side, and freight can be booked as soon as the production date is firm. The critical path is normally the safety assessment, which is why starting it early is the cheapest way to protect a launch date.
Conclusione
Importing cosmetics into France is not difficult, but it is unforgiving of shortcuts. The regulation asks for a small number of things done properly: a Responsible Person established in the EU, a CPSR signed by a qualified assessor, a PIF that matches the product, a CPNP notification made before the first sale, and a French-language label that carries the right information. The French authorities enforce these through unannounced inspections and sampling, so the file has to be ready before the goods are.
2026 has added moving parts. Fragrance allergen labelling, the end of duty-free treatment for low-value parcels, new packaging rules and the pending Omnibus VI package all change the picture for importers and forwarders. The sensible approach is to build the compliance file first, keep it current, and treat logistics as part of the same project. Topway Shipping works with importers on the freight side of that project, from FCL and LCL ocean bookings and customs clearance to overseas warehousing and last-mile delivery, so that the cargo arriving in France matches the paperwork behind it.
DOMANDE FREQUENTI
Q: Do cosmetics need a CE mark to enter France?
A: No. Cosmetics are governed by Regulation (EC) No 1223/2009, which relies on a Responsible Person, a safety report, a PIF and CPNP notification instead of CE marking.
Q: Is one CPNP notification enough for all EU countries?
A: Yes. Once a product is notified in the CPNP by the Responsible Person, no further national notification is needed in other member states. The UK is separate and requires its own notification.
Q: Who can act as my Responsible Person if I have no EU company?
A: A specialist regulatory company established in the EU can be designated by written mandate. Its name and address then appear on the label.
Q: Must the CPSR and PIF be in French?
A: The label must be in French. The ANSM has indicated that PIF documents are preferably in French but that English is acceptable.
Q: How long must the PIF be kept?
A: For ten years after the last batch of the product is placed on the market.
Q: Does the €3 EU duty apply to a container shipped to an importer?
A: No. The interim €3 duty targets low-value B2C consignments of up to €150 shipped from outside the EU. Containers imported for resale follow the normal tariff and VAT rules.