Private label cosmetics for EU brands, made in India

Brands and importers in the European Union can source private label cosmetics from India, provided each product meets the EU Cosmetics Regulation, Regulation (EC) No 1223/2009, before it is placed on the market. The regulation applies across all member states, so one set of core rules covers the EU. National authorities in each member state carry out market surveillance. We manufacture in our own facility in Ambala, Haryana, India, and supply the technical information. The EU responsible person completes the local steps. This page sets out who is responsible, what must happen before sale, how labels work and which documents to expect from us.

Who is legally responsible when you sell cosmetics in the EU?

The regulation allows a cosmetic product onto the EU market only if a legal or natural person established in the EU is designated as its responsible person. That person ensures the product meets the regulation's obligations.

For an imported product, the regulation makes each importer the responsible person for the products it places on the market. The importer can instead designate, by written mandate, another person established in the EU to take the role, who must accept in writing. A distributor becomes the responsible person if it places a product on the market under its own name or trademark, or changes it in a way that could affect compliance.

For private label goods made in India, the responsible person is therefore the EU importer, the EU brand owner or a specialist service they appoint. It is not us. We make the product and provide the data the responsible person needs.

What has to happen before products go on sale?

1. Safety assessment and cosmetic product safety report. Before the product is placed on the market, the responsible person must make sure it has undergone a safety assessment and that a safety report has been drawn up. The assessment takes account of intended use and exposure to the ingredients.
2. Product information file (PIF). The responsible person keeps a PIF for each product. It holds a product description, the safety report, a description of the manufacturing method with a statement on compliance with good manufacturing practice, and proof of claimed effects where the nature or effect of the product justifies it. It is kept available at the address on the label.
3. Notification through the CPNP. The responsible person submits product information electronically through the Cosmetic Products Notification Portal (CPNP) before placing the product on the market. The European Commission states that once a product is notified in the CPNP, no further national notification is needed within the EU.

Products containing nanomaterials need a separate notification on top of the standard one, and certain nanomaterial colourants, preservatives and UV filters need explicit authorisation. Raise this at the brief stage.

We supply the inputs: the formula and INCI list, specifications, raw material and fragrance data, stability and compatibility information, and details of the manufacturing method. The safety assessor and responsible person build the report, the PIF and the notification from these.

What goes on an EU cosmetic label, and in which language?

The language of most label information is set by the law of the member state where the product is sold to the end user. A product sold in several countries may need several languages, or a separate label for each market. Items an EU label typically carries include:

• Responsible person. Name and address of the responsible person, and the country of origin for imported products, for example "Made in India".
• Nominal content by weight or volume.
• Durability. A date of minimum durability, or for longer-lasting products a period-after-opening symbol.
• Precautions for use, including those the regulation's annexes require for certain ingredients.
• Batch number or another reference that identifies the product.
• Function of the product, unless it is clear from its presentation.
• Ingredient list headed "ingredients", using common ingredient names. Fragrance is shown as "parfum", with certain fragrance substances named where required, and nanomaterials are marked "(nano)".

Keep claims cosmetic, and have artwork reviewed by your responsible person or adviser before print.

Which documents will your EU importer ask us for?

Our testing and documents service prepares the product paperwork. Our facility is ISO certified and GMP-compliant; these are facility facts, not an EU approval or notification for any product.

Which ranges suit the EU market?

Any ready formula can be considered once it has been checked against the EU ingredient annexes. These ranges match common EU private label briefs:

• Skincare, where a clear INCI list and complete raw material data make the safety assessment straightforward.
• Makeup, where colourants must be checked against the EU list of permitted colourants before you commit to shades.
• Body care, including body wash, lotions and butters, where fragrance allergen data shapes the label.
• Eco and refillable packaging, for brands that want refill formats; the pack still needs compatibility information for the safety report.

How does an order to the EU work with us?

1. Brief. List the products, the member states you will sell in and your responsible person.
2. Shortlist and sample. Choose ready formulas; samples are available on request. Ready formulas start from 500 units per product.
3. Ingredient check. Your adviser checks each formula against the EU annexes. Where a change is needed, custom formulation is quoted per brief.
4. Documents. We supply the technical inputs for the safety report and PIF.
5. Labels. Artwork is prepared in the languages of each member state where you sell.
6. Local steps. The responsible person completes the safety report, PIF and CPNP notification.
7. Production and shipment through our fulfilment and export service.

Timelines depend on the formula, the number of label languages and approval speed. See how it works and our guide to exporting cosmetics from India.

Next step

Send your product list, target member states and responsible person details through the inquiry form for EU orders. We will confirm the documents we can prepare and how we can ship. EU rules and ingredient annexes are amended regularly, so always confirm current requirements with your importer, responsible person or a regulatory adviser before placing products on the market.