Cosmetics Compliance & Regulations Guide for Private Label Brands | MetaCNBeauty
Cosmetics Compliance & Regulations Guide
A practical, plain-English guide to cosmetics compliance for private label brand founders, Amazon sellers, and distributors importing cosmetics from China. Covers US FDA MoCRA, EU EC 1223/2009, UK, Australia, Canada, and Amazon requirements. Updated May 2026.
Compliance by market
Select your target market to jump directly to the relevant compliance requirements.
At a glance — all markets
| Market | Regulation | Key requirement | Who files | MetaCNBeauty provides |
|---|---|---|---|---|
| 🇺🇸 US | FDA MoCRA (21 CFR) | Facility registration + product listing | Brand owner (importer) | GMPC cert, INCI, MSDS, COA, country of origin |
| 🇪🇺 EU | EC 1223/2009 | Responsible Person + CPSR + CPNP | EU Responsible Person | ISO 22716 GMP cert, INCI, MSDS, COA |
| 🇬🇧 UK | UK Cosmetics Regulation | UK RP + CPSR + SCPN registration | UK Responsible Person | ISO 22716 GMP cert, INCI, MSDS, COA |
| 🇦🇺 AU | AICIS / NICNAS | Industrial chemical notification (if applicable) | Importer / brand owner | INCI, MSDS, COA, country of origin |
| 🇨🇦 CA | Health Canada (CPA) | Cosmetic notification filing | Brand owner (importer) | INCI, MSDS, COA, country of origin |
| 📦 Amazon | Amazon cosmetics policy | GMP cert + INCI + MSDS + COA | Seller (you) | GMP cert, INCI, MSDS, COA, HS codes |
US FDA Cosmetics Compliance
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is the most significant update to US cosmetics law in over 80 years. It introduced mandatory facility registration, product listing, safety substantiation, and adverse event reporting for cosmetics sold in the United States. If you sell cosmetics in the US — including via Amazon.com — MoCRA applies to you.
🏭 Facility registration
Every facility that manufactures or processes cosmetics for US sale must register with the FDA. MetaCNBeauty’s Guangzhou facility is subject to this requirement. Registration must be renewed every two years.
- Who registers: the facility owner (MetaCNBeauty) or the brand owner
- Deadline: facilities must be registered
- Renewal: every 2 years (odd-numbered years)
- Free to register via FDA Cosmetics Direct portal
📝 Product listing
Each cosmetic product sold in the US must be listed with the FDA. Product listing includes the product name, ingredients (INCI), and responsible party contact information.
- Who lists: the brand owner (you) or the facility
- Required for every SKU sold in the US
- Must include full INCI ingredient list
- Update required when formula changes
- Free to file via FDA Cosmetics Direct portal
🛡️ Safety substantiation
MoCRA requires that cosmetics are safe for their intended use. You must maintain safety substantiation records for each product. MetaCNBeauty’s INCI lists, MSDS, and COA form the foundation of your safety file.
🏥 Adverse event reporting
Serious adverse events (e.g. infections, injuries) must be reported to the FDA within 15 days. Maintain a record of all consumer complaints and adverse events for each product.
🏷️ Labeling requirements
US cosmetics labels must include: product name, net quantity, ingredient list (INCI, descending order), manufacturer/distributor name and address, and any required warnings.
EU Cosmetics Compliance
EU Cosmetics Regulation EC 1223/2009 is one of the world’s most stringent cosmetics regulatory frameworks. It applies to all cosmetics sold in EU member states. The regulation requires a Responsible Person (RP) established in the EU, a Cosmetic Product Safety Report (CPSR) prepared by a qualified safety assessor, and notification via the CPNP portal before any product can be placed on the EU market.
👤 Responsible Person (RP)
Every cosmetic product sold in the EU must have a Responsible Person — a legal entity established in the EU who takes legal responsibility for the product’s compliance. The RP can be the brand owner (if EU-based), a distributor, or a third-party RP service.
- Must be established in an EU member state
- Legally responsible for product compliance
- Maintains the Product Information File (PIF)
- Third-party RP services available (cost: €50–€300/product/year)
📊 Cosmetic Product Safety Report (CPSR)
A CPSR must be prepared by a qualified safety assessor (toxicologist) for each product before EU market entry. The CPSR assesses the safety of the formula based on the INCI ingredient list, usage conditions, and exposure data.
- Required for every SKU sold in the EU
- Must be prepared by a qualified safety assessor
- Based on INCI list, MSDS, and usage data
- Typical cost: €150–€500 per product
- MetaCNBeauty provides INCI + MSDS to support CPSR
💻 CPNP notification
Before placing a product on the EU market, the RP must submit a notification via the Cosmetic Products Notification Portal (CPNP). Includes product name, category, country of origin, RP details, and INCI list.
📁 Product Information File (PIF)
The RP must maintain a PIF for each product, including: product description, CPSR, GMP compliance evidence (ISO 22716 cert), manufacturing data, and safety monitoring records.
🏷️ EU labeling
EU labels must include: product name, function, INCI list, net quantity, best before date (if <30 months), PAO symbol, warnings, RP name and address, country of origin, and batch number.
UK Cosmetics Compliance
Following Brexit, the UK operates its own cosmetics regulatory framework, largely mirroring EU EC 1223/2009 but with separate requirements. Cosmetics sold in Great Britain (England, Scotland, Wales) must comply with the UK Cosmetics Regulation and be notified via the Submit Cosmetic Product Notifications (SCPN) portal. Northern Ireland continues to follow EU rules under the Windsor Framework.
🇬🇧 UK Responsible Person
A UK RP established in Great Britain is required for all cosmetics sold in GB. This is separate from the EU RP — you need both if selling in both markets. The UK RP maintains the UK Product Information File and is legally responsible for compliance.
- Must be established in Great Britain
- Separate from EU RP (post-Brexit)
- Third-party UK RP services available
- Typical cost: £50–£200/product/year
💻 SCPN notification
All cosmetics sold in Great Britain must be notified via the OPSS Submit Cosmetic Product Notifications (SCPN) portal before market entry. Notification includes product name, category, INCI list, RP details, and country of origin.
- Required before placing product on GB market
- Filed by the UK RP
- Separate from EU CPNP notification
- Free to submit via OPSS portal
📊 UK CPSR
A UK Cosmetic Product Safety Report is required, prepared by a qualified safety assessor. Equivalent to the EU CPSR but must reference UK regulatory standards. MetaCNBeauty’s INCI lists and MSDS support your UK CPSR process.
🏷️ UK labeling
UK labels must include a UK address (not EU). “Made in China” country of origin required. INCI list, net quantity, PAO, warnings, and batch number as per EU requirements. “GB RP” must be stated on label or packaging.
Australian Cosmetics Compliance
Australia regulates cosmetics primarily through the Australian Industrial Chemicals Introduction Scheme (AICIS), which replaced NICNAS in 2020. Unlike the US and EU, Australia does not require pre-market approval for most cosmetics — but importers must ensure all ingredients are listed on the AICIS Inventory and comply with labeling requirements under the Trade Practices (Consumer Product Information Standards) regulations.
📋 AICIS inventory check
All cosmetic ingredients must be listed on the AICIS Inventory (formerly AICS). Most standard cosmetic ingredients are already listed. Novel or new-to-Australia ingredients may require introduction notification or assessment.
- Check each INCI ingredient against AICIS Inventory
- Most standard cosmetic ingredients are listed
- Novel ingredients may require notification
- MetaCNBeauty provides full INCI lists for checking
🏷️ Australian labeling
Australian cosmetics labels must include: product name, net quantity, importer name and Australian address, INCI ingredient list (descending order), directions for use, and any required warnings. “Made in China” country of origin is required.
🛡️ Therapeutic claims
Cosmetics making therapeutic claims (e.g. “treats acne”, “reduces wrinkles”) may be regulated as therapeutic goods by the TGA (Therapeutic Goods Administration) rather than as cosmetics. Avoid therapeutic claims on cosmetics labels.
Canadian Cosmetics Compliance
Canada regulates cosmetics under the Cosmetic Act and associated regulations administered by Health Canada. The key requirement for imported cosmetics is a Cosmetic Notification filed with Health Canada within 10 days of first sale in Canada. Canada also maintains a Cosmetic Ingredient Hotlist — a list of prohibited and restricted ingredients.
📝 Cosmetic notification
A cosmetic notification must be filed with Health Canada within 10 days of first sale in Canada. The notification includes product name, manufacturer details, importer details, and full ingredient list. Filed via Health Canada’s online portal. Free to file.
🚫 Ingredient hotlist
Health Canada maintains a Cosmetic Ingredient Hotlist of prohibited and restricted substances. All ingredients in your product must be checked against the Hotlist before sale in Canada. MetaCNBeauty’s INCI lists support this check.
🏷️ Canadian labeling
Labels must be bilingual (English and French). Must include: product name, net quantity, manufacturer/importer name and Canadian address, INCI ingredient list, and any required warnings. “Made in China” country of origin required.
Amazon Cosmetics Compliance
Amazon has its own cosmetics compliance requirements that operate alongside — and sometimes exceed — the regulatory requirements of each market. Amazon may request compliance documentation at any time, including at listing creation, during account reviews, or following customer complaints. Being prepared with the right documents prevents listing suppression and account suspension.
📄 Documents Amazon may request
- GMP certificate — ISO 22716 or GMPC (MetaCNBeauty provides both)
- Full INCI ingredient list — required for all cosmetics listings
- MSDS / Safety Data Sheet — required for shipping and compliance
- Certificate of Analysis (COA) — batch-specific quality test results
- Country of origin — “Made in China” must be declared
- HS codes — for customs classification
⚠️ Amazon-specific rules
- No drug claims on cosmetics listings (e.g. “treats acne” = drug claim)
- Ingredient list must match physical label exactly
- Products must comply with the regulations of the Amazon marketplace country
- EU Amazon: requires EU RP and CPNP notification
- UK Amazon: requires UK RP and SCPN notification
- US Amazon: MoCRA facility registration and product listing recommended
Key compliance terms explained
Plain-English definitions of the most important cosmetics compliance terms.
INCI
International Nomenclature of Cosmetic Ingredients. The standardised scientific naming system for cosmetic ingredients used on labels worldwide. Required on all cosmetics labels in the US, EU, UK, AU, and CA.
MSDS / SDS
Material Safety Data Sheet (also called Safety Data Sheet). Documents the safety properties, handling requirements, and hazard information for a cosmetic product. Required for international shipping and customs clearance.
COA
Certificate of Analysis. A batch-specific document confirming that a product has been tested and meets its specification. Includes physical and chemical test results.
GMP / ISO 22716
Good Manufacturing Practice. ISO 22716:2007 is the international standard for cosmetics GMP. Referenced in EU EC 1223/2009. MetaCNBeauty holds ISO 22716 GMP certification issued by DEKRA.
GMPC
Good Manufacturing Practice for Cosmetics based on U.S. FDA guidelines. MetaCNBeauty holds GMPC certification issued by DEKRA. Supports FDA MoCRA compliance documentation.
Responsible Person (RP)
A legal entity established in the EU or UK who takes legal responsibility for a cosmetic product’s compliance with EC 1223/2009 or UK Cosmetics Regulation. Required for EU and UK market entry.
CPSR
Cosmetic Product Safety Report. A safety assessment prepared by a qualified toxicologist, required for EU and UK market entry. Based on the product’s INCI list, MSDS, and usage data.
CPNP
Cosmetic Products Notification Portal. The EU online portal where Responsible Persons notify cosmetic products before EU market entry. Separate from the UK SCPN portal.
MoCRA
Modernization of Cosmetics Regulation Act (2022). US law requiring cosmetic facility registration, product listing, safety substantiation, and adverse event reporting for cosmetics sold in the United States.
Compliance questions from private label buyers
Do I need to comply with regulations if I sell online only?
Yes. Cosmetics regulations apply based on where the product is sold and consumed — not how it is sold. If you sell online to US customers, FDA MoCRA applies. If you sell to EU customers, EC 1223/2009 applies.
Can MetaCNBeauty handle compliance for me?
MetaCNBeauty provides all technical manufacturing documentation (GMP certs, INCI, MSDS, COA). Our Compliance Team can assist with regulatory filings (RP, CPSR, MoCRA, CPNP) at buyer’s cost. Ask us about compliance support →
Is a GMP certificate enough for EU market entry?
No. GMP certification (ISO 22716) is a required component of the EU compliance process but is not sufficient on its own. You also need a Responsible Person, CPSR, and CPNP notification. GMP cert is part of the Product Information File (PIF).
Do I need separate compliance for each country?
Yes. Each market has its own regulatory framework. EU and UK are separate post-Brexit. US, AU, and CA each have their own requirements. Amazon compliance is additional to national regulations.
What happens if I sell non-compliant cosmetics?
Consequences vary by market: product seizure, import refusal, listing removal (Amazon), fines, and in serious cases, legal liability. Compliance protects your brand, your customers, and your business.
How long does compliance take to set up?
US MoCRA registration: 1–2 weeks. EU RP + CPSR + CPNP: 4–12 weeks depending on CPSR assessor availability. UK: similar to EU. AU: no pre-market approval required for standard cosmetics. CA notification: 1–2 weeks.
Need compliance support for your market?
MetaCNBeauty provides all technical documentation. Our Compliance Team can assist with regulatory filings in the US, EU, UK, AU, and CA — at buyer’s cost.
📧 Inquiry@metacnbeauty.com | 💬 +86 135 4124 4178 | 📍 Guangzhou, China