Exporting cosmetics to Poland

The Responsible Person

A manufacturer outside the EU cannot be the Responsible Person itself. It appoints the importer, a distributor or a specialised service company in the EU in writing. The Responsible Person makes sure the product complies, keeps the Product Information File (PIF) at the address on the label for 10 years after the last batch, notifies the product in CPNP and reports serious undesirable effects.

What goes into the product file

• the Cosmetic Product Safety Report (part A: data; part B: the assessor's conclusion), signed by a qualified safety assessor,
• the product description and formula, method of manufacture and a statement of good manufacturing practice (ISO 22716 is the usual reference),
• proof of the effects claimed,
• data on any animal testing done for the EU: testing finished cosmetics and ingredients on animals for the EU market is banned.

Ingredients and claims

The EU Cosmetics Regulation lists more than 1,600 banned substances and many restricted ones, colorants, preservatives and UV filters that may be used only as listed. Products made with nanomaterials need a notification six months before sale. Skin-lightening creams containing mercury or hydroquinone are banned in the EU and regularly appear in alerts on the EU Safety Gate system for dangerous non-food products.

Claims must be truthful and supported by evidence. A product that claims to treat or prevent a disease is a medicine, not a cosmetic: this matters for herbal and Ayurvedic products.

The Polish label

The container and packaging must show the name and address of the Responsible Person, the nominal content, the date of minimum durability or the period after opening symbol, precautions, batch number, the function of the product and the INCI ingredient list. Poland requires this information in Polish (the INCI list stays in INCI). Cosmetics in Poland are supervised by the State Sanitary Inspection.