Importing cosmetics from China into the EU: CPNP and responsible person

Regulation (EC) No 1223/2009 of 30 November 2009 on cosmetic products is the single text that governs the manufacture, safety assessment and labelling of every cosmetic product made available on the European Union market, with its most recent consolidated version dated 1 September 2025. It applies in the same way to a product manufactured in a member state and to a product manufactured in China and then imported: origin changes none of the obligations, it simply adds one step, designating a representative established in the Union.

The text's stated aim is a high level of protection for human health. A Chinese manufacturer already selling on its domestic market has none of these documents by default: they must be built specifically for the European Union, product by product.

The responsible person is the entity established in the European Union that answers, before the authorities, for a cosmetic's compliance with regulation 1223/2009. Without one, a cosmetic manufactured outside the Union cannot legally be placed on the European market, regardless of the product's actual quality.

This role can be held by the manufacturer itself if it has an entity in the EU, by the importer, by an agent designated in writing by the non-EU manufacturer, or by a distributor that markets the product under its own name or brand. The agreement designating the responsible person must be in writing and kept on file, as it is one of the documents the authorities can request during an inspection.

A Chinese factory cannot fill this role from China: it is not established in the Union. It therefore falls to the European importer, or to an agent it designates, to take on this role before the first sale.

CPNP notification is the mandatory electronic filing, on the European Cosmetic Product Notification Portal, of a cosmetic's information before its first placement on the Union market. Article 13 of regulation 1223/2009 sets out what the responsible person must provide: product category, name and address of the responsible person, country of origin if imported, member state where the product is first placed on the market, contact details in case of emergency, presence of nanomaterials, presence of substances classified as carcinogenic, mutagenic or toxic for reproduction.

One often-misunderstood point works in the buyer's favour: a single CPNP notification covers the whole European Union market, with no additional country-by-country national notification. On the other hand, the logic changes as soon as the same product changes brand or trade name: a distributor that takes an already-notified cosmetic but renames it or applies its own brand is in turn treated as a responsible person and must file its own notification, separate from that of the original manufacturer or importer.

Notification must happen before placing the product on the market, never after: a product sold without CPNP notification is in breach from the very first unit sold.

The product information file, or PIF, is the set of documents the responsible person must compile for each cosmetic and keep available to the authorities for ten years after the last manufactured batch is placed on the market. It gathers the product description, its qualitative and quantitative formula, manufacturing methods, evidence supporting claimed effects, and above all the cosmetic product safety report, often referred to by its English acronym CPSR.

The CPSR is made up of two distinct parts. Part A gathers the raw data: qualitative and quantitative composition, physico-chemical properties and stability, microbiological quality, impurities and traces, information on the packaging material. Part B is the assessment itself, the risk evaluation drawn from that data, written and signed by a qualified safety assessor.

This qualification is not left to the importer's discretion: article 10 of regulation 1223/2009 requires a degree or university training in pharmacy, toxicology, medicine or a similar discipline, or training recognised as equivalent by a member state.

Article 19 of regulation 1223/2009 sets out the list of details that must appear on the container and the packaging of a cosmetic, in indelible, easy-to-read and visible characters. These details are not negotiable with the factory: they apply regardless of the country of manufacture.

Nominal content is declared by weight or volume at the time of packaging, except for products under 5 grams or 5 millilitres, free samples and single-use doses. A minimum durability date is mandatory as long as durability does not exceed thirty months, in the form month and year or day, month and year, preceded by the symbol set out in Annex VII or the corresponding wording. Beyond thirty months, it is replaced by the period-after-opening symbol, an open jar, together with a duration in months or years.

The ingredient list, preceded by the word INGREDIENTS, is presented in descending order of weight; below 1% concentration, the order is free. Names must follow the COSING database nomenclature, and a nanomaterial is flagged with the mention [nano] attached to its name.

Taking an existing formula from a Chinese factory to sell it under your own brand, as private label, remains a common way to launch a cosmetics range without developing an entire formula. The general logic of the model is covered in our article on white label and private label; on the cosmetics side, it runs into a specific constraint of regulation 1223/2009: changing the brand or trade name makes you a responsible person in your own right, with your own CPNP notification and your own PIF, even if the formula and manufacturer remain identical to those of a product already sold elsewhere in the Union.

This rule has a direct effect on timing: a competitor's notification for the same product sold under another brand exempts you from nothing. Each brand carries its own responsibility, unless there is an explicit agreement with the holder of an existing notification to reference it.

Packaging deserves separate attention: beyond the labelling required by the cosmetics regulation, placing packaging on the market triggers separate extended producer responsibility obligations, specific to each member state, which add to regulation 1223/2009 without replacing it.

Sorva is a brokerage and sourcing house active between Europe and China. Our Chinese-speaking team in Guangzhou identifies and verifies cosmetics factories able to supply the technical documentation your file needs, formula, packaging materials, manufacturing processes, while our engineering office frames the regulatory compliance study and the technical product file that feed your responsible person's PIF.

In most cases you pay no fees on the supplier search: you open a file with us, we negotiate the goods for you and we take a commission on their ex-works value. The regulatory compliance study and the technical product file are billed separately, ahead of production, to secure your notification before committing to the order.