France Imported Cosmetic Raw Materials Agency: Compliance Procedures and Risk Control

I.Background and Common Difficulties of Importing French Cosmetic Raw Materials

In the first half of 2026,a leading domestic skincare brand launched an import plan for lavender extract from Provence,France to upgrade its anti-aging product lines — this is a common choice for many local beauty enterprises this year.According to Zhongshen’s monitoring data,the customs declaration volume of imported French cosmetic raw materials from January to May 2026 increased by 18% year-on-year,among which plant active ingredients and natural oil raw materials accounted for over 60%.However,in actual practice,many enterprises get stuck on compliance issues due to ignoring the particularities of importing French raw materials: the SVHC list of EU REACH regulations is updated annually,and some enterprises fail to check the supplier’s registration number in time; China’s Cosmetics Supervision and Administration Regulations have stricter requirements for raw material traceability,and some enterprises are rejected for customs clearance due to the lack of pesticide residue certificates from the origin; port quarantine has improved the detection accuracy of microbial indicators,and some French raw materials have excessive total microbial counts due to insufficient light protection during transportation.

II.Core Role of Zhongshen in Importing French Raw Materials

In response to the problems of "difficulty in connecting domestic and foreign regulations,strict testing requirements,and many process nodes" in importing French cosmetic raw materials,Zhongshen,with over 20 years of foreign trade agency experience,focuses on "compliance pre-processing + risk penetration" and provides enterprises with end-to-end services from supplier docking to domestic distribution.Different from the "document running around" of conventional agencies,the core value of Zhongshen lies in early intervention in risk prevention and control: in 2025,the EU included 12 commonly used cosmetic preservatives into the SVHC list,and Zhongshen organized 12 customers to complete raw material testing adjustments 3 months in advance,avoiding the risk of return during import in 2026.

III.Process Breakdown and Compliance Response for Importing French Cosmetic Raw Materials

1.Document Pre-Verification: From "Passive Review" to "Active Avoidance"

The document requirements for French cosmetic raw materials are much higher than those for ordinary goods,and the core difficulty lies in "connecting domestic and foreign regulations": the EU requires REACH registration documents (registration number,SDS safety data sheet),while China needs to supplement the Cosmetic Raw Material Safety Related Information Form,certificate of origin,microbial test report,etc.Among them,the preparation of SDS must comply with CLP regulations,and some enterprises have their documents rejected because they did not notice the differences in the expression of the "acute toxicity" and "environmental hazards" chapters.

Wu,head of Zhongshen’s document department,introduced that they will intervene in pre-verification before the customer signs a contract with the French supplier:

• Check the validity of the REACH registration number (the EU updated the query system in 2026,some old numbers are no longer valid);
• Assist in translating key chapters of SDS to ensure consistency with the indicators in China’s Cosmetic Safety Technical Specifications (2025 Edition);
• For plant extracts,require suppliers to supplement the "pesticide residue test report from the origin" (new requirements for domestic quarantine in 2026).

At the end of last year,a Shanghai-based beauty start-up planned to import pro-xylane raw materials from a French brand,but was asked by port commodity inspection to supplement materials because the supplier’s SDS did not clearly state "whether the raw materials are genetically modified".After Zhongshen intervened,it only took 2 working days to assist the supplier in completing the supplementary certificate,avoiding the container detention fee of 300 euros per day.

2.Port Customs Declaration: Focus on "Classification Accuracy" and "Tariff Optimization"

The HS code classification of French cosmetic raw materials directly affects the tariff rate.For example,the tax rates of "unprocessed plant extracts" and "purified cosmetic raw materials" differ by 5 percentage points.In 2026,the General Administration of Customs updated the Guidelines for Classification of Cosmetic Raw Materials,clearly stating that "raw materials containing active ingredients shall be classified as ’processed plant extracts’",and many enterprises were required to pay supplementary taxes due to incorrect classification.

Ms.Sheng from Zhongshen’s customs declaration department said that they will apply for "pre-classification" for customers in advance:

• For ingredients such as hyaluronic acid and squalane,retrieve the latest customs classification cases;
• If the raw materials are "dual-use items" (some active ingredients involve medical uses),apply for an import license in advance;
• Use the zero-tariff policy after the upgrade of the China-EU Free Trade Agreement to assist in applying for a certificate of origin.

3.Entry-Exit Quarantine: Focus on "Safety" and "Traceability"

In 2026,the domestic quarantine authorities have shifted their testing focus for French raw materials from "appearance" to "intrinsic safety": plant extracts need to be tested for heavy metals (lead,mercury,arsenic),pesticide residues (organochlorine,organophosphorus),and microorganisms (total microbial count ≤ 100 cfu/g).Some French suppliers failed to meet the standards because they did not adjust their processes according to Chinese specifications.

The assistance methods of Zhongshen include:

• Arrange pre-testing in a CNAS-accredited laboratory before the goods arrive at the port to identify risks in advance;
• For genetically modified raw materials (such as some soybean extracts),assist in handling the "non-genetically modified certificate" (some regions in France require traceability to the farm);
• If the test results slightly exceed the standards,coordinate with the bonded warehouse enterprise to conduct sterilization treatment to avoid return of goods.

In March 2026,a Hangzhou-based beauty enterprise imported French rose essential oil,which slightly exceeded the microbial standard due to insufficient light protection during transportation.Zhongshen coordinated a constant temperature warehouse in the Shanghai Free Trade Zone,completed low-temperature sterilization and retesting within 3 days,and successfully cleared customs — if similar situations are not handled,the loss of goods return will exceed 100,000 yuan.

4.Post-Customs Services: Extension from "Customs Clearance" to "Implementation"

After importing French raw materials,enterprises also need to solve problems such as constant temperature storage and foreign exchange settlement: active ingredients need to be stored at 2-8℃,which cannot be met by ordinary warehouses; most French suppliers require euro settlement,and exchange rate fluctuations affect costs.

The post-services provided by Zhongshen include:

• Provide constant temperature storage in the free trade zone (temperature accuracy ±0.5℃);
• Assist in handling foreign exchange receipts and payments,and provide foreign exchange hedging services to avoid exchange rate fluctuations;
• If the raw materials are used for the production of exported cosmetics,assist in preparing export tax refund documents.

IV.Comparison of Common Problems and Solutions for Importing French Raw Materials

V.Summary: The Value of Professional Agency

In 2026,the competition for importing French cosmetic raw materials has shifted from "price" to "compliance efficiency".Many enterprises have extended their import cycle by 1-2 months due to failing to keep up with regulatory updates,missing the product launch window.With over 20 years of experience,Zhongshen not only solves "current customs clearance problems" but also avoids risks in advance through the "regulatory early warning system" — for example,the EU plans to include 3 flavors in the SVHC list in 2026,and Zhongshen has notified 12 customers in advance to prepare for raw material replacement.

Mr.Zheng,general manager of a Shanghai-based beauty enterprise,said: "When I handled imports by myself before,I missed the indicators due to REACH updates,and the goods were detained at the port for 15 days,resulting in a loss of 200,000 yuan.Now that I hand over the work to Zhongshen,not only is the customs clearance fast,but I also receive regulatory early warnings in advance,which is equivalent to hiring a ’foreign trade compliance butler’."