Cosmetic Products

Introduction to Cosmetics in the EU Market

The EU Market is the largest and most desired export market in the world for cosmetic and personal care products. In 2017 alone, personal care product sales accounted for 77.6 billion euros.

The complexity of the regulatory framework in Europe and the ongoing updates related especially to ingredients used in cosmetic products might challenge Brand Owners in having their products effectively placed on the EU Market without the support and assistance of a professional EU Responsible Person.

From July 11, 2013, the Cosmetic Regulation EC 1223/2009 became fully applicable in the EU as the main legal framework for cosmetic products.

Key Facts:

  • Any product made available in the EU Market (either through e-commerce or brick-and-mortar) must comply with the Cosmetic Regulation EC 1223/2009
  • Non-EU manufacturers wishing to make their products available to EU citizens must appoint an EU Responsible Person
  • Manufacturer is defined in 1223/2009/EC, art 2.1 (d) as:
any natural or legal person who manufactures a cosmetic product or has such a product designed or manufactured, and markets that cosmetic product under his name or trademark
  • Products which fail to comply with the regulatory framework may be subject to public notification (RAPEX- Rapid Alert System for Non-Food Consumer Products), withdrawal requirements, fines or total destruction of the products.

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