Private Label Cosmetics and Skincare From China: Rules

Start with the selling market, formula and claims

Whether you are launching a brand, buying for a small retailer or importing at scale, give the supplier a written brief covering destinations, intended users, intended use, claims and packaging. Choose the selling markets before approving production.

Ask for the complete formula with ingredient concentrations and supporting specifications. Arrange confidential disclosure to the safety assessor if necessary, and ensure the Responsible Person can fulfil their documentation duties. A retail ingredient list alone does not provide all the information needed for a safety assessment.

Use the sequence below as a suggested buying workflow. The Great Britain example concerns England, Scotland and Wales; check other destinations separately.

Order of operations: from brief to launch

First: define the product, destinations and proposed claims. Resolve classification before promising effects on labels or advertising.

Next: identify the local compliance roles and have the formula reviewed before paying for custom packaging. For Great Britain, use the guides to appointing a Responsible Person and screening ingredient restrictions.

Then: verify the actual production site and its manufacturing evidence. Follow checking cosmetics factory GMP evidence, and check that any certificate covers the relevant site and activity.

Next: agree an identified formula and packaging sample, the assessor’s evidence requirements, testing responsibilities and change controls. Request reports that can be traced to that version.

Before placing the product on the market: complete the destination’s safety documentation, approve final artwork and complete the required notifications. For Great Britain, follow the PIF and safety assessment guide, then the SCPN notification guide.

Finally: inspect the production batch against the agreed specification, reconcile shipping documents and release goods for sale only after the applicable compliance requirements are met. Agree who keeps batch records and handles complaints.

Pre-order checklist

Use this as a purchasing gate before committing to bulk production. Record the owner and outstanding evidence for each item.

Testing and factory evidence: ask product-specific questions

For the Great Britain safety assessment, the evidence addresses stability, microbiological quality and relevant packaging characteristics. Ask the assessor which stability, microbiological quality and preservative efficacy tests are needed, including challenge testing where applicable. Any omission of otherwise required data needs a scientific justification accepted by the assessor. Agree a product-specific testing plan.

Ask whether the evidence covers the agreed formula and intended packaging and supports the proposed storage conditions and shelf life. Do not use satisfactory appearance on arrival as the sole acceptance criterion.

For Great Britain, manufacture must comply with good manufacturing practice. Compliance with ISO 22716 can demonstrate this; it is not the only route. As a purchasing check, verify the document’s issuer, site and scope. Obtain product-specific safety evidence separately.

Great Britain worked example: responsibility, documents and labels

For direct imports from China into Great Britain, a UK-established Responsible Person must ensure compliance. Before placing the product on the market, obtain a safety assessment by a suitably qualified assessor, include the Cosmetic Product Safety Report (CPSR) in the Product Information File (PIF), and notify through SCPN. Northern Ireland has a separate process.

Review the final label for the Responsible Person’s name and address, country of origin, nominal content, minimum durability or period-after-opening information as applicable, precautions, batch identification, product function and ingredients. Check applicable exceptions, transitional provisions, language and presentation requirements before printing.

Screen the formula against current GB ingredient prohibitions, restrictions and conditions of use. Use the linked specialist guides for the detailed ingredient, documentation and notification procedures.

Great Britain worked example: customs value and import VAT

Budget customs costs separately from product compliance. HMRC requires relevant transport, insurance and associated delivery costs up to the applicable UK place of introduction to be included in customs value. Import VAT valuation starts with customs value and adds applicable import duties and charges, excluding the import VAT itself, plus relevant incidental expenses to the first UK destination and any further UK destination known at importation. Do not count costs twice.

Confirm classification, valuation and applicable rates for the actual shipment. Ask the supplier to identify which import costs are included in any delivered quote.

If you sell in the US or EU

US — checked 2026-10-18: under MoCRA, the responsible person must ensure and maintain records supporting adequate safety substantiation. Facility registration and product listing requirements have exemptions. Registration or listing does not indicate FDA approval.

US entry — checked 2026-10-18: CBP states that using a broker does not remove the importer of record’s responsibility for correct entry documentation and applicable duties, taxes and fees. Check USTR’s China Section 301 tariff actions and any applicable exclusions against the product’s tariff classification; assess the shipment’s other applicable import charges separately.

EU — checked 2026-10-18: responsible persons, and distributors in certain circumstances, must submit cosmetic product information through CPNP. Once a product is notified through CPNP, no further national cosmetic product notification is needed within the EU.

Buying support from Cambridge China Bridge

When enquiring about private label cosmetics sourcing, prepare your formula brief, destinations, proposed claims, quantities and supplier documents. Ask who would arrange specialist assessments and laboratory work.

When enquiring about factory verification, specify the supplier checks and goods inspections you need. Request written confirmation of the scope, deliverables, fees and any third-party costs before commissioning work.