Sourcing beauty and personal care products from China

The obligations land on you, and they land before you sell

Cosmetics is the category where the paperwork has to be finished before the product goes on sale, not alongside it. Every cosmetic product placed on the Great Britain market must have a Responsible Person with a UK established address, and if you are importing from China and selling under your own brand, that is almost certainly you.

Being the Responsible Person is not a title. It means holding the Product Information File, ensuring the product has undergone a safety assessment with a cosmetic product safety report produced, and notifying the product before it is placed on the market through the Submit Cosmetic Product Notification service.

The sequencing matters more here than in most categories. A container of finished cosmetics with no safety assessment is not a product with a paperwork gap; it is stock you cannot legally sell while you commission the work that should have come first.

What the file actually has to contain

The Product Information File is the evidence behind your product: the description, the safety report, the manufacturing method and a statement of good manufacturing practice, proof of any claimed effect, and data on animal testing where relevant.

The safety assessment has to be done by someone qualified, and it is based on the actual formulation. That means you need the full quantitative formula from your manufacturer, not a marketing ingredient list, and you need it before the assessment can be done.

This is the point where a lot of Chinese cosmetics suppliers become difficult, because the formulation is their intellectual property. Establish early whether they will disclose it to your safety assessor under confidentiality. A supplier who will not is a supplier you cannot legally launch with.

Ingredients and claims

Restricted and prohibited substances apply, and preservative systems, colourants and UV filters are the usual areas where a formulation made for another market does not translate. A product formulated for the Chinese domestic market is not automatically acceptable here.

Claims have to be supportable. Anything sounding medicinal moves the product out of cosmetics entirely and into a different regime, so language such as treats, heals or cures needs care rather than enthusiasm.

Labelling requirements are specific: ingredient listing in the correct convention, durability information, batch identification, function, warnings and the Responsible Person's name and address. Get the artwork checked before printing, because relabelling a container of stock is expensive and looks it.

Manufacturing quality, which is not the same as compliance

Ask about good manufacturing practice and whether the site works to a recognised standard. Ask how batches are recorded and whether a finished unit can be traced to a raw material batch, because that is what makes a problem a withdrawal rather than a catastrophe.

Specify fill weight and tolerance, viscosity, colour and fragrance against retained standards, pack integrity and closure torque, and stability including how the product behaves after temperature cycling. Cosmetics fail in transit and on shelf in ways that a fresh sample will not show you.

Require batch codes and expiry or period-after-opening marking as a specification item, not an assumption.

Packaging, which is half the product here

In beauty the pack is a large part of what the customer is buying, and it is also where compliance and practicality meet. Pumps, droppers and airless bottles are the components that fail most often, so name them and require approval for substitution.

Test the pack with the actual formulation over time rather than empty. Compatibility problems between a formula and its container appear weeks later, which is after your first order has shipped.

And remember packaging producer responsibility and plastic packaging tax apply to what you place on the market.

A workable sequence

Confirm the supplier will disclose the full formulation under confidentiality. Get the formulation reviewed for GB acceptability before tooling any artwork. Commission the safety assessment and build the Product Information File. Finalise labelling against the assessment. Notify before placing on the market. Then order production, inspect, and keep the file current for every reformulation.

Done in that order it is methodical. Done in reverse it is a container of unsellable stock and a rushed assessment on a formula that may not pass.