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Export Cosmetics from the USA

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This article explains the measures, procedures, and documents needed to export cosmetics from the United States to overseas markets. It also introduces ways to keep costs and issues down, along with key points by country.

Key Regulatory Points
for Exporting Cosmetics
from the United States

Exporting cosmetics from the United States involves regulations and procedures that differ from those for domestic sales. Understanding practical export requirements is important, including the role of the FDA, whether export permits are required, and whether information and documents related to ingredients and safety must be submitted. Additionally, preparing the necessary documents to meet the destination country’s requirements can help prevent shipment delays caused by customs clearance issues.

Role of the FDA and Export Requirements

The FDA is the regulatory agency overseeing cosmetic safety and labeling in the United States. Export-related matters are outside the scope of the FDA, and the agency does not make determinations regarding permits or other approvals. However, even for exports, basic requirements such as ingredient safety assessments and INCI labeling must be followed. Moreover, appropriate action is required when the importing country requests a Certificate of Free Sale (CFS).

Is an Export License Necessary?

In most cases, exporting cosmetics from the United States is generally not subject to a government export license requirement. Cosmetics are treated as consumer products, and they can be exported and sold as long as they comply with the importing country’s regulations.

However, products that claim therapeutic, preventive, or diagnostic effects may be considered drugs. The same applies in cases where products fall under OTC drugs, such as acne treatments, antiperspirants, and UV products, as they may also be considered drugs. Products that fall under these categories may be subject to drug regulations, which may require additional export procedures.

Key Documents Required for Export

In international trade, regardless of the type of product, there are several essential documents required for import and export. For cosmetics, materials that include ingredient information are required in addition to the basic documents. The following are examples of required documents, but additional documents may be required depending on the destination country.

  • Commercial Invoice
  • Packing List
  • SDS
  • Ingredient List (INCI)
  • Certificate of Free Sale (issued by a state)

Documents such as INCI and CFS are used by the importing country’s authorities when assessing safety.

How to Check Import
Regulations that Vary
by Export Destination

When exporting cosmetics, it is more important to understand the destination country’s regulations and rules than those of the United States. Each country establishes its own ingredient standards, labeling conditions, and registration procedures. Failure to comply with regulations or rules creates the risk that sales permits may not be granted or that products may be held at customs.

Understanding the Destination Country’s Regulations Is Key

The reality is that cosmetic regulations and rules differ from country to country. Even products that can be legally sold in the United States may contain ingredients that are banned in other countries or violate labeling regulations. Each country has its own banned and restricted ingredients, and the language and content of labeling also vary. When exporting cosmetics, problems can be prevented by verifying and complying with the destination country’s regulations and rules.

Four Essential Regulatory Points
to Check

Ingredient regulations
(prohibited ingredients)

Prohibited and restricted ingredients vary by country. The EU is strict, and ingredients permitted in the United States may still be prohibited in the EU.

Labeling
(language and required information)

U.S. specifications are not acceptable, and labeling in the local language is required. Required information includes INCI ingredients, net contents, responsible party information, and country-of-origin labeling.

Animal testing rules

The EU and the UK ban data derived from animal testing. China may be exempt under certain conditions, but requirements vary by category.

Need for product registration
and notification

Procedures vary by country, such as CPNP notification in the EU and NMPA registration in China. Ingredient information must also be submitted.

Key Logistics Points
for Reducing Costs and Problems
in Cosmetic Exports

When exporting cosmetics from the United States, it is important to comply with the destination country’s regulations. Each country has its own product registration system, including rules for cosmetic ingredients, labeling regulations, and the treatment of animal testing. If a product is prepared solely according to U.S. standards, it may be detained at customs. Export regulations differ significantly by country, so it is essential to verify basic points such as prohibited ingredients, labeling requirements, and registration systems.

Choosing Appropriate
Transportation Methods for Cosmetics

While air transportation allows for quick delivery, products containing alcohol may be classified as hazardous materials and might not be eligible for air transport. Although maritime transport can reduce costs, significant temperature fluctuations within containers can cause fragrances and emulsion products to deteriorate.

In particular, liquids and creams are susceptible to temperature changes and physical impact, and their quality can be affected by the transportation method. It is important to select an appropriate transportation method and adjust packaging based on the product’s ingredients and properties, as well as the season.

Understanding
the Costs Incurred
in the Export Process

Exporting cosmetics entails multiple costs, including shipping, customs fees, and insurance premiums. In addition, products classified as hazardous materials may incur additional costs. Depending on the destination country, product registration costs may also apply. To prevent unexpected costs, it is necessary to estimate the total amount in advance and secure extra funds.

How to Choose a Reliable
Carrier or Forwarder

Forwarders with experience in shipping cosmetics may be well versed in hazardous materials classification and document preparation. This can improve transport stability and optimize costs, helping prevent export-related issues as well.

When selecting a forwarder, verify its track record in handling cosmetics and whether it has knowledge of customs procedures in the destination country. It is also necessary to confirm the forwarder’s level of understanding of INCI and SDS. If the forwarder provides packaging support, suitable packaging can be arranged to match the product and the season.

Registration Applications
and Sales Strategies
to Keep in Mind for
Cosmetic Sales in China

There are two methods to sell cosmetics in China: general trade and cross-border e-commerce. In the case of general trade, registration with the NMPA is required. In contrast, cross-border e-commerce allows cosmetics to be sold without registration. Although many products are exempt from animal testing, they must meet certain conditions. The page below explains registration with the NMPA and other important considerations when selling cosmetics in China.