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Journal · Wholesale · 4 min read

Natural cosmetics wholesale: what retailers should check

Definition, mandatory documents, labelling and supplier checks: the key questions before your first order, with references to EU law.

In brief

‘Natural cosmetics’ is not legally defined in the EU; the INCI list and documents are what count.

Every cosmetic product needs a Responsible Person in the EU, a safety report and a CPNP notification.

Check samples, INCI list, label and terms in writing before you order.

What does ‘natural cosmetics’ mean legally?

The term is not defined in EU law. A product’s character is shown by its ingredient list (INCI) and the manufacturer’s documents; private standards and labels each set their own criteria.

ISO 16128 offers guidelines for calculating the natural and natural-origin content of ingredients. It is not a certification. If a supplier mentions a label, ask for the valid certificate for the specific product, not only for the company.

Which documents must a cosmetics supplier provide?

Every cosmetic product in the EU needs a Responsible Person established in the EU, a Cosmetic Product Safety Report, a Product Information File and a notification in the CPNP. As a retailer, ask for confirmation of who the Responsible Person is and that the product has been notified.

Obligations under Regulation (EC) No 1223/2009
ObligationPurposeArticle
Responsible PersonEnsures compliance with the regulationArt. 4, 5
Good manufacturing practiceManufacture to a recognised standard, e.g. EN ISO 22716Art. 8
Cosmetic Product Safety Report (CPSR)Assessment of safety for human healthArt. 10, Annex I
Product Information FileAll product documents, available to authoritiesArt. 11
CPNP notificationNotification before placing on the marketArt. 13
LabellingMandatory information on the packagingArt. 19

Sources: Regulation (EC) No 1223/2009 (EUR-Lex) · Cosmetic Products Notification Portal (CPNP).

What must appear on the label of a cosmetic product?

Mandatory information includes the name and address of the Responsible Person, nominal content, durability marking, batch number, function, precautions where required and the ingredient list. It must be in the language required in the country of sale.

A date of minimum durability is required for products that keep for 30 months or less. For longer-lasting products, the open-jar symbol states the period after opening instead. For products imported from outside the EU, the country of origin must also be stated. Legal basis: Article 19 of Regulation (EC) No 1223/2009 (EUR-Lex).

What applies to claims for natural cosmetics?

Cosmetic claims must be truthful, supported by evidence, honest and fair, and must not highlight features that are merely legal requirements. The common criteria are set out in Regulation (EU) No 655/2013.

Ask for evidence before adopting claims such as ‘moisturising’ or ‘for sensitive skin’ in your shop. ‘Free from’ claims for substances that are banned anyway are not permitted. Source: Regulation (EU) No 655/2013 on cosmetic claims (EUR-Lex). This guide is not legal advice.

How do I assess a natural cosmetics supplier?

Order samples, request INCI lists and label drafts, and have prices, minimum quantities, lead times and delivery terms confirmed in writing. Ask who the Responsible Person is and how complaints are handled.

  • Do durability and remaining shelf life on delivery suit your sales cycle?
  • Are labels available in the language of your market, or will you need to relabel?
  • Is there a fixed contact person and a reachable business address?
  • Are shipments within the EU single market, so that no customs duties apply?

Once samples and documents are in order, start with a written offer and a first order of manageable size, to test sell-through and logistics before ordering larger quantities.

Last updated: October 2026This page provides general information on cosmetics and trade practice. It is not legal, tax or medical advice.

FAQ

Frequently asked questions

Do I need a certification to sell natural cosmetics?

No. EU law does not require a natural cosmetics certification. Certification schemes are voluntary; if you advertise one, the certificate must cover the specific product.

Am I liable as a retailer for the products I sell?

Distributors have their own duties under Article 6 of Regulation (EC) No 1223/2009, such as checking labelling and storage conditions. The main responsibility lies with the Responsible Person.

Are cosmetics from Spain subject to customs duties in the EU?

No. Spain is part of the EU single market. VAT rules for intra-Community supplies apply between VAT-registered businesses.

What is a Responsible Person in cosmetics?

The Responsible Person is the company or person in the EU that ensures a cosmetic product complies with Regulation (EC) No 1223/2009. Their name and address must appear on the label. Details in our EU regulation guide.

Do I have to notify the products in the CPNP as a retailer?

Normally not; the notification is done by the Responsible Person. A distributor only has to notify certain information if they make a product available in another member state on their own initiative and translate the labelling for it.

Can I translate the labels myself?

If a distributor modifies the labelling, for example by translating it, they can take on the obligations of the Responsible Person under Article 4(6) of the Regulation. It is safer to agree the label languages with the supplier.

How do I check a supplier’s labels?

Check the name and address of the Responsible Person, nominal content, durability, precautions, batch number, function and the INCI list. Our INCI guide helps with the ingredient list.

What should a first wholesale order include?

A small, clearly defined range that suits your customers is usually best, for example one product from each of two or three categories. Order samples first; see the wholesale page.

Where can I check the rules for selling cosmetics outside the EU?

Our export guide summarises the rules for Switzerland, the UK, the USA, Canada and Australia, with links to the official sources.

Is a wholesaler the same as a distributor under EU cosmetics law?

Under Regulation 1223/2009, every business in the supply chain after the manufacturer or importer that makes products available is a distributor, including wholesalers and retailers.

All questions

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