Importing Skincare/ Cosmetics from Non-EU

[ukieb]

Read some old thread from here but still wondering certain things.

I am planning to resell skincare/ cosmetics imported from non-EU countries in the UK. After doing some research, my understanding is that your importing needs to fulfill the EU safe test, labeling requirement and register on CPNP if you import from the non-EU country. However, I found quite a few websites selling Asian products without the proper labeling at least, and I'm not quite sure if they do the test or registration or not.

Here are my questions.
1) Are there any exemptions to the EU cosmetics regulations, e.g. sell online instead of in-store. Otherwise, are those websites operating illegally as they are Ltd companies registered in the UK?
Shall I assume that they did the testing and registration and sell the same product by making my own label?

2) What is the least document I need to provide if I do the importing? Consider I'm going to start from a small scale soft opening, my buyer will do the purchase on the retail market and post them to me. So I may not have a commercial invoice.

 

[Mr D]

If you import you become responsible.
Online or offline, labelling and testing remain the same. As is capacity for legal action against you.

Your buyer will have some sort of receipt? Showing price paid etc?
Usually a lot more expensive to import retail value products than wholesale for the same quantity.

 

[ukieb]

If you import you become responsible.
Online or offline, labelling and testing remain the same. As is capacity for legal action against you.

Your buyer will have some sort of receipt? Showing price paid etc?
Usually a lot more expensive to import retail value products than wholesale for the same quantity.

Yes, that's my understanding from my research.
1) I don't know how those "competitors" able to get rid of the regulations?
2) If I purchase from them, are they the responsible person in this case?
3) Can I still import them even if they are not tested and make my own label to stick on the product? What documents do I need to provide in order to clear/ pass the custom?
4) The receipts would be exactly the same as those you get from a retail shop, except in a foreign language. Is the declaration form attached to the parcel good enough to act as a purchase invoice? As you need to declare the value and also the import VAT, etc.

 

[Mr D]

Yes, that's my understanding from my research.
1) I don't know how those "competitors" able to get rid of the regulations?
2) If I purchase from them, are they the responsible person in this case?
3) Can I still import them even if they are not tested and make my own label to stick on the product? What documents do I need to provide in order to clear/ pass the custom?
4) The receipts would be exactly the same as those you get from a retail shop, except in a foreign language. Is the declaration form attached to the parcel good enough to act as a purchase invoice? As you need to declare the value and also the import VAT, etc.

1 Perhaps they haven't. Just haven't been caught yet.
2. Yes so long as its their brand, their label etc. I presumed you wanted your own.
3 You run risks if you don't get the product tested. You personally run risks.
4 You'd be having the receipts in the package.

 

[ukieb]

2. Yes so long as its their brand, their label etc. I presumed you wanted your own.

No, I don't make my own product. I just resell those ready-made products import from Non-EU countries. It is obvious that I couldn't make my import meet the regulations by doing testing due to the cost.
So what if I purchase those items from competitors/ any other wholesale suppliers in the UK. Will they become responsible capacity in this case?

 

[MOIC]

It's for the importer of the products to ensure compliance.

As a reseller, you must carry out due diligence that the products are correctly certified and are safe for use in the country you are selling in.

You must have product liability, as a minimum.

 

[Mr D]

No, I don't make my own product. I just resell those ready-made products import from Non-EU countries. It is obvious that I couldn't make my import meet the regulations by doing testing due to the cost.
So what if I purchase those items from competitors/ any other wholesale suppliers in the UK. Will they become responsible capacity in this case?

Then you have to make sure the imported stuff meet regulations by doing testing.
Cost is your problem, not doing it can cost you far more.

Purchasing from UK suppliers (have no clue why competitors will sell to you) then yes they are responsible and if there are problems can supply you necessary paperwork.
There are multiple skincare suppliers who are reputable.

As my office in china says you must have product liability. Your insurer may have their own concerns which UK reputable suppliers can resolve.

 

[QPLAST]

Incase of import, the importer is responsible for the statuary compliance of the product. This changes from country to country.

If you are looking for sustainable business, then you must do all the testing and obtain compliance for your intended products.

There are many international test labs. So check with your supplier, if they can provide you the compliance certificates(from internationally recognized labs) of their own country. It may be easier to show their compliance report and get re-validated in the UK.

Import is a better option, only when there is a huge volume and you have repeat business. To begin with, you may buy from local manufacturer and understand the compliance requirements of UK.

All the best.

Cheers, Deepak

 

[CHUKTC]

Importing cosmetics as you have rightly found out has a lot of regulatory compliance attached to it and is not for the feint hearted. AS others have said given the effort required it is only really cost effective if you are looking for good volumes. You are right there are many online sellers who openly flout the regulations (not just in the cosmetics field) and they are just too small and too numerous for trading standards to catch up with them all. However all it takes is one customer to get a bad reaction and complain to trading standards and they can find themselves in very deep trouble.
If you feel you business is ready to import then do all the registration and start by purchasing products which have all the required certification AND are already importing the product to somewhere in Europe. This will reduce your costs considerably.

 

[WKW]

Does all CPNP requirements still apply if the product you wish to import is already available for sale within the UK market? Do you have to re-register the product?

I am also looking to import from outside of the EU however the products I am hoping to sell are already available via large retailers such as Cult Beauty and Feel Unique etc. Does that mean that company has already carried out the necessary checks and registered the product for sale in EU via the CPNP?

 

[Mr D]

Does all CPNP requirements still apply if the product you wish to import is already available for sale within the UK market? Do you have to re-register the product?

I am also looking to import from outside of the EU however the products I am hoping to sell are already available via large retailers such as Cult Beauty and Feel Unique etc. Does that mean that company has already carried out the necessary checks and registered the product for sale in EU via the CPNP?

If you are buying from a UK supplier then no. They will already have done the relevant requirements and provide the documentation on request.