Customs DeclarationCosmetics & Personal CareEnterprises exporting to the EU market face an important compliance challenge: whether REACH registration is required? This is not only a product compliance issue, but also a test of corporate strategy. This article will explain the requirements of this regulation in detail to help enterprises better understand and address this challenge.

First of all, it is crucial to clarify the scope of application of the Cosmetics Regulation (CPR) and the EU REACH Regulation.

Cosmetics Regulation (CPR)
EU Regulation No. 1223/2009: Standardizes cosmetic safety standards, labeling and packaging requirements.

REACH regulation
EU Regulation No. 1907/2006: Applies to all chemicals entering the EU market and requires preventive management.

The different forms of cosmetics will directly affect their different regulatory requirements:

Finished cosmetic products
需要應對CPR法規(guī)，同時按REACH法規(guī)要求，視為特殊配制品，需進行REACH注冊。

Cosmetic raw materials
Only subject to the REACH regulation, substances with an annual production or import volume of ≥ 1 ton need to be registered under REACH.

Next, we will explain the key issue encountered in the REACH registration of cosmetic raw materials: Will the animal testing ban affect REACH registration?

New substances used in cosmetics
If only used in cosmetics, exposure of consumers or professionals can be exempted from animal testing data. If there is exposure to workers, the data requirements for REACH registration need to be met, and the animal ban does not apply.

Substances not limited to cosmetic use
Complete toxicological data needs to be submitted, and animal testing is feasible.

Although animal testing is allowed under the REACH regulation, the EU encourages the use of non - animal testing methods such as in vitro testing, Read - across, etc. as the preferred way to obtain data.

When cosmetic enterprises deal with REACH registration, the following key points should be considered:

Animal testing and non - animal testing
Animal testing can be used as a means to obtain high - quality data, but non - animal testing methods should be considered first.

Data requirements and technological progress
With the development of non - animal testing technologies, it is expected that more new technologies will be applied to the REACH registration of cosmetic raw materials in the future.

Strategy suggestions
Consider the animal ban and REACH requirements, and adopt appropriate testing methods to ensure compliance.

In the international trade of the cosmetics industry, understanding and complying with the regulations of the target market is the key to success. For enterprises exporting to the EU, understanding and adapting to the REACH registration requirements is not only a legal obligation, but also a market access strategy. By comprehensively considering the requirements of the CPR and REACH regulations, enterprises can ensure product safety while effectively entering and stabilizing their position in the EU market.