EU Regulatory Regime · High
Cosmetics Regulation 1223/2009 — importer obligations + worked example
Status
Status: Active since 2013.
What you must do as the importer
Designate a Responsible Person (RP) established in the EU. Notify each product on the Cosmetic Product Notification Portal (CPNP). Maintain Product Information File (PIF) including safety assessment by qualified assessor. Comply with Annex II (banned), Annex III (restricted), Annex IV-VI (colorants/preservatives/UV filters) lists.
What goods are covered
- 33 — Essential oils, perfumery, cosmetics
- 3304 — Beauty/make-up preparations
- 3305 — Hair preparations
- 3306 — Oral hygiene preparations
- 3307 — Pre-shave/shaving/depilatories
Worked example: a typical shipment that triggers
A €50,000 shipment of cosmetics (HS 330000) from CN into the EU triggers Cosmetics Regulation 1223/2009. The customs duty + VAT are calculated as normal — but on top of that, the importer must satisfy the obligations above before the goods can be placed on the EU market.
Non-compliance is not a duty event — it is a market-access event
A common misunderstanding: importers focus on duty + VAT and treat compliance as a tickbox. EU customs increasingly hold goods at the border for missing documentation (DDS for EUDR, CBAM declarant status for steel/aluminium, EU Responsible Person for cosmetics). Holds become storage charges; storage charges become forced re-export. Validate before booking the freight.
Related OrcaTrade resources
See whether this regime applies to your specific shipment
Six questions, all four calculators (sourcing, routing, customs, warehouse), full landed cost — with this regime flagged on your specific HS code if applicable.
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