One of the most common misconceptions in cosmetic exporting is the belief that CE marking applies to cosmetics. This is incorrect and can lead to costly compliance mistakes. Under European Union regulations, cosmetic and personal care products are not subject to CE marking requirements. Instead, cosmetics must comply with EU Cosmetic Regulation (EC) No 1223/2009, which requires CPNP (Cosmetic Products Notification Portal) registration, CPSR (Cosmetic Product Safety Report), and REACH compliance for ingredients.
Cosmetic and personal care products are not subject to CE marking requirements under EU regulations. Compliance is achieved through CPNP notification, safety assessment, and ingredient restrictions per Regulation (EC) No 1223/2009 [1].
For exporters targeting the United States, the regulatory landscape changed significantly with the Modernization of Cosmetics Regulation Act (MoCRA) enacted in 2023. FDA facility registration is now mandatory for cosmetic manufacturing facilities, with the first biennial renewal deadline set for July 1, 2026. However, it's critical to understand that FDA registration is not certification - the FDA does not issue certificates for cosmetic product facility registrations, and registration does not constitute approval of products (except for color additives).
FDA Registration Status: Over 14,000 facility registrations and nearly 1 million product listings recorded. Biennial renewal required - first deadline July 1, 2026.
For B2B buyers seeking manufacturing partners, ISO 22716 GMP certification remains the global gold standard for cosmetic production. This standard covers guidelines for production, control, storage, and shipment of cosmetics. A significant development: France's DGCCRF is expected to make ISO 22716 certification compulsory by late 2026 or early 2027. However, for the US market, NSF/ANSI 455-3 is emerging as the preferred standard, aligned with MoCRA requirements. Notably, ISO 22716:2007 has remained unchanged since 2007, while NSF/ANSI 455-3:2024 undergoes annual revisions - leading some US buyers to potentially phase out ISO 22716 in favor of the more current NSF standard.
Cosmetic Certification Comparison: Requirements by Market
| Certification/Registration | EU Market | US Market | Mandatory? | Key Requirements |
|---|
| CE Marking | Not Applicable | Not Applicable | No | Cosmetics exempt from CE marking |
| CPNP Registration | Required | N/A | Yes (EU) | Product notification before market entry |
| FDA Facility Registration | N/A | Required | Yes (US) | Biennial renewal, July 1 2026 first deadline |
| ISO 22716 GMP | Voluntary (France compulsory 2026-27) | Recognized | No | Production/control/storage/shipment GMP |
| NSF/ANSI 455-3 | Limited recognition | Preferred emerging standard | No | MoCRA-aligned, annual updates |
Note: Small businesses may have exemptions under MoCRA, but not for eye products, injectables, or internal use products.