A Chinese factory can make your serum, lip balm or perfume. It cannot sell it for you in Europe. Before the first unit goes on sale, someone in the EU or UK must take legal responsibility for it, and that someone is often you.
This guide covers what the EU and UK require for cosmetics made in China, and what to settle with the factory before you order. It is one of several compliance checks. For general product safety rules, see our GPSR guide. Cosmetics have their own regulation, and it comes first.
The responsible person
Both markets ask for a named responsible person. The responsible person makes sure the product meets the law, and authorities contact them first if something goes wrong.
| EU | Great Britain | |
|---|---|---|
| Law | Regulation (EC) No 1223/2009 | UK cosmetics regulations, guidance from the Office for Product Safety and Standards (OPSS) |
| Who | The importer is the responsible person for an imported product (Article 4(5)) | A named responsible person with a UK or EU address |
| Factory in China | Cannot hold the role | Cannot hold the role |
The EU rule is clear in the regulation: “each importer shall be the responsible person for the specific cosmetic product he places on the market.” If you bring the goods in, you carry the duty, unless another EU-based person accepts it in writing.
On Great Britain, two OPSS pages use different wording. The cosmetics guidance says the responsible person has “a UK or EU address”. An OPSS news item says businesses notify “via their Responsible Person based in the UK”. Check with OPSS or a regulatory adviser which applies to you before you print a label. The OPSS guidance covers England, Scotland and Wales. Northern Ireland follows the EU rules.
What the responsible person must have
- A safety assessment. The Commission says manufacturers follow set requirements when preparing a product safety report before the product goes on the market. GOV.UK says a new product “must be assessed by a qualified professional, to confirm it is safe.”
- Notification before sale. In the EU, Article 13 requires the responsible person to submit the product information electronically to the Commission before placing the product on the market. The notification includes the name and address of the responsible person where the product information file is available, and the country of origin for an import. In Great Britain, the product must also be notified to the OPSS.
- A product information file. The notification points to the address where this file is “made readily accessible”. Ask the factory for the formula, test data and manufacturing details early. Many factories can supply some of this. Ask what they hold.
What the label must show
Under Article 19(1) of the EU regulation, the container and packaging carry the required information in “indelible, easily legible and visible lettering”. Two items matter for an importer:
- The name and address of the responsible person.
- The country of origin for imported products. For a product made in China, the label states that.
The language rules differ by market. GOV.UK says the label information for Great Britain must be in English. In the EU, Article 19(5) leaves the language of certain items to each member state where the product reaches the end user.
The label is the visible proof of compliance. A box printed without the responsible person’s address needs a sticker or a reprint. Confirm the text with the factory before the print run, not after. Our packaging design service can help prepare the artwork.
Before you order
- Name your responsible person
You as importer, or a service provider in the EU or UK who agrees in writing. Do this before the label is designed.
- Ask for the product information
Ask the factory for the full ingredient list, test reports and manufacturing details. Check that the formula on the documents matches the product.
- Get the safety assessment done
A qualified professional in your market reviews the formula and writes the safety report. Allow time for it before the first order.
- Notify the product
The responsible person submits the notification in the EU portal or to the OPSS before the first sale.
- Approve the label proof
Check the responsible person details, country of origin and ingredient text against your notes before printing.
- Check labels at inspection
Add the label content to the inspection checklist so the inspector checks it on the finished goods.
Perfume, liquids and shipping
Cosmetics ship as ordinary cargo in many cases, but liquids and perfume can need special handling by air. Ask your forwarder about your product before you book. Our guides to shipping from China to the UK and to the EU cover routes and costs.
How CFS helps
We check the factory’s documents and labels before production and inspect the finished goods against your checklist. Our quality control and supplier verification services cover that. We do not write safety reports. A qualified assessor in your market does that.
Bottom line
The factory makes the product. The responsible person makes it legal to sell. Name that person first, get the safety assessment and notification done, and approve the label proof before printing.
Checked against EUR-Lex, the European Commission and GOV.UK on 13 November 2026. This guide is general information, not legal advice. Ask a regulatory adviser about your own products.
Questions we get asked
Who is the responsible person for cosmetics imported from China into the EU?
The importer. Article 4(5) of Regulation (EC) No 1223/2009 says each importer is the responsible person for the cosmetic product it places on the market. Another EU-based person can take the role if they accept it in writing.
Do I need to notify a cosmetic product before I sell it?
Yes. In the EU, the responsible person notifies the Commission electronically before the product goes on the market, through the CPNP portal. In Great Britain, the product must be notified to the Office for Product Safety and Standards.
What must be on the label?
The name and address of the responsible person, and the country of origin for imported products. In Great Britain this information must be in English. In the EU, some label information must be in the language of each member state where you sell.
Can my Chinese factory be my responsible person?
Not on its own. The responsible person must have an address in the EU, or an address in the UK or EU for Great Britain. A factory in China does not meet that test, so an importer or a service provider in the market takes the role.