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Cosmetic importation from extra-EU countries: economic benefit in compliance with the European regulations

It often happens that extra-EU companies, and sometimes even people coming back from China, Philippines, Iran and other, think that they can easily import cosmetic products into the European Union, believing that the process is very simple.

On the contrary, it is very important to stress that the cosmetic products marketed in the EU must comply with the safety requirements provided for by the European regulations. In particular, the person importing cosmetic products into the EU is directly responsible of the products marketed in the European territory and must therefore ensure that raw materials and manufacturing are in compliance with the standards of the cosmetic good manufacturing practice (NBF) (UNI EN ISO 22716).

This document establishes the guidelines for the manufacturing, control, storage and shipment of cosmetic products with the purpose of ensuring high hygiene, health and safety standards to the final user.

For this reason, before importing cosmetic products from these countries, its advised to select the supplier based on inspections to be carried out directly at the extra-EU manufacturing site in order to verify that quality procedures are in place in compliance with the European standards as well as qualified personnel charged with the control of the manufacturing steps.

Following such inspection, a report can be released certifying the compliance of the Extra-EU supplier with the cosmetic NBF.

Another aspect to be taken into account is that the European importer (Responsible Person) shall keep the PIF (Product Information File) available for the Competent Authorities of the Member States where they market the cosmetic products for each cosmetic product put on the market and deliver it, on request, with no delay.

This dossier, to be kept updated in the post-marketing phase, contain all chemical and physical characteristics, microbiological quality, toxicology and safety assessment of the cosmetic product and of the raw materials it contains.

It is therefore important to import cosmetic products from a reliable and transparent manufacturer in order to make easy any exchange of technical information required for the drafting of the PIF.

After the online notification of a cosmetic product in the online portal of the European Commission, the responsible Person can market it in the EU.

Ensuring the safety of the product is a responsibility falling on the company, however there is a network of control by the Authority for the cosmetic surveillance on the Union territory for the protection of the final users.

A European system is active in the EU for the alert on hazardous products other than food (Rapid Alert System) for the exchange of information between Member States on non compliant cosmetic products.

The Italian Authority for the surveillance of cosmetic products on the market is the Ministry of Health, performing a controlling role through the competent body, a dedicated task force for counterfeiting (NAS).

Reports of non compliant cosmetics are several. These are withdrawn from the market after the NAS inspections with consequent application of burdensome fines.

Before importing cosmetic products from an extra-EU country it is therefore necessary to take all the actions required to ensure the compliance with the European regulations. This will allow the free circulation of the goods with the primary goal of increasing the safety of the final user.

Written by: Giorgia Martini