Analysis of Customs Declaration Process and Compliance Key Points for French Cosmetics Import

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In the Shanghai cosmetics import market in 2026,F(xiàn)rench brands account for over 15% of the total,but import customs declaration often puts enterprises at risk of delay due to multi-departmental supervision and complex compliance requirements for ingredients. The core issue is how to balance efficiency and compliance. Mr. Fan,General Manager of Zhongshen,pointed out that importing French cosmetics requires focusing on key links such as raw material filing and label review,and agency services can shorten the customs clearance cycle through pre-advance review and other methods.。

In the Shanghai cosmetics import market in 2026,high-end skincare and makeup products from French brands remain popular,and many local traders and e-commerce platforms are targeting this segment.However,customs declaration for imported French cosmetics is no easy task — the differences between EU cosmetics regulations and China’s supervision requirements,the complexity of raw material ingredient filing,and the strict standards of port commodity inspection often cause many enterprises to suffer setbacks in the customs clearance process.For example,last year,a Shanghai trading company imported a French brand’s essence,but failed to review the matching degree between the ingredients and China’s regulations in advance,resulting in the requirement to supplement testing during the commodity inspection stage,delaying the shipment by nearly 20 days and missing the sales peak season.

As a Shanghai-based enterprise with over 20 years of experience in foreign trade agency services,Zhongshen has fully understood every pain point of importing French cosmetics.From document pre-review to port customs clearance and subsequent commodity inspection,the Zhongshen team will follow up the entire process to prevent risks for clients in advance.

3 Common Problems and Solutions for French Cosmetics Import Customs Declaration

1.Document Pre-Review: The First Barrier to Compliance

The document requirements for importing French cosmetics are more complex than ordinary goods,with the core lying in the alignment of EU and China’s regulatory rules.Ms.Mai,Head of the Document Department at Zhongshen,told us that many clients who are new to French cosmetics import tend to overlook two key issues: first,the Chinese notarization of the EU Cosmetic Safety Report (CSR),and second,the matching degree between raw material ingredients and China’s Cosmetics Safety Technical Specifications (2025 Edition).

Unique Document Compliance Requirements for French Cosmetics

  • EUCosmeticSafetyReport(CSR):MustcomplywithEC1223/2009Regulation,betranslatedintoChineseandnotarizedbyanotarypublic,andsupplementedwithariskassessmentstatementwithinChina
  • Rawmaterialingredientlist:MustbemarkedwithINCIInternationalNomenclatureofCosmeticIngredients.ForsomecommonlyusedactiveingredientsinFrance(suchascertainplantextracts),third-partytestreportsmustbeprovidedtoprovethattheymeetthesafetylimitsspecifiedinChina’sregulations
  • CertificateofOrigin:MustbeissuedbyrelevantFrenchinstitutionsandcertifiedbyacertificationbodyrecognizedbyChina’sGeneralAdministrationofCustoms
  • Labelsample:MustcomplywithChina’sCosmeticLabelManagementMeasures.Forexample,ingredientsmustbelistedindescendingorderofcontent,andnomedicalefficacyclaimsareallowed

Ms.Mai will communicate with clients 10-15 days in advance to review the completeness and compliance of all documents.For example,last year,a client only provided a CSR that included EU risk assessments.Ms.Mai found that the usage scope of one of the ingredients was restricted under China’s regulations,and immediately advised the client to supplement the China-specific risk assessment report for that ingredient,avoiding the subsequent return of the customs declaration.

2.Port Customs Declaration: Accurate Classification to Avoid Tariff Pitfalls

In the customs declaration process for French cosmetics,commodity code classification is the most error-prone part.Mr.Zhuang,Head of the Customs Declaration Department at Zhongshen,said that for skincare products,the codes for ordinary moisturizing cream and anti-wrinkle serum are different,and the tariff rate difference can reach 2-3 percentage points; for lipsticks and eyeshadows in makeup,the codes also need to be clearly distinguished.Incorrect classification will not only lead to overpayment of tariffs,but may also trigger customs inspections.

Special Precautions for French Cosmetics Customs Declaration

3 Common Problems and Solutions for French Cosmetics Import Customs Declaration

  • Commoditycodeclassification:Mustbeaccuratelyclassifiedbasedontheproduct’singredients,efficacyandusage.Forexample,skincareproductswithsunprotectionfunctionsmustbedeclaredunderthesunprotectionproductcode
  • Dutiablevaluecalculation:Mustincludefreight,insurancepremiums,etc.Donotonlydeclaretheproduct’sownprice,otherwisethecustomswillreassesstheprice
  • Declarationinformationverification:Efficacyclaimsmustbeconsistentwiththefiledrecords.Forexample,nomedicalefficacyclaimssuchas"treatingsensitiveskin"areallowed,otherwisethecustomswillraisequestions

Mr.Zhuang will accurately determine the code based on the product parameters provided by the client and in accordance with China’s Customs Tariff.For example,in 2025,a client imported a French brand’s sun protection isolation cream,which was initially incorrectly classified as ordinary skincare product (code 3304990090).Mr.Zhuang found that its sun protection index was SPF50+,which meets the sun protection product code (3304990010).After adjustment,the tariff rate dropped from 10% to 6%,saving the client nearly 50,000 yuan in tariffs.

3.Commodity Inspection Stage: Early Communication to Avoid Testing Delays

The commodity inspection requirements for French cosmetics are strict,especially for microbial and heavy metal testing.Mr.Wu,Head of the Commodity Inspection Department at Zhongshen,said that in 2026,China’s commodity inspection sampling rate for imported cosmetics has increased by 15% compared to last year.Some French brands are prone to exceeding the total aerobic bacterial count in microbial testing due to differences in production processes.

Special Quarantine Requirements for French Cosmetics

  • Microbialtest:Totalaerobicbacterialcount≤1000CFU/g,totalmoldandyeastcount≤100CFU/g(compliantwithChina’sCosmeticsSafetyTechnicalSpecifications2025Edition)
  • Heavymetaltest:Lead≤10mg/kg,Mercury≤1mg/kg,Arsenic≤2mg/kg(SpecialattentionrequiredforsomeFrenchnaturalcosmetics)
  • Animaltestingcertificate:Iftheproducthasnotundergoneanimaltesting,a"NoAnimalTestingCertificate"mustbeprovidedtocomplywithChina’sanimaltestingalternativerequirements

Mr.Wu will communicate with the commodity inspection agency in advance to understand the latest testing requirements.For example,last year,a client imported a French brand’s natural facial mask and was worried about failing the microbial test.Mr.Wu recommended a qualified third-party testing agency in advance,allowing the client to conduct a pre-test before shipping to ensure the product meets the standards.Eventually,the commodity inspection sampling passed at one go,and the customs clearance certificate was obtained in only 3 days.

4.Practical Case: From 20-Day Delay to 7-Day Customs Clearance

In October 2025,a Shanghai trading company planned to import a French brand’s high-end eye cream for sale during the Double 11 Shopping Festival.However,during the first customs declaration,the CSR was not translated into Chinese and notarized,and one active ingredient in the formula was not filed in the Cosmetics Safety Technical Specifications,resulting in the customs declaration being returned,delaying the shipment by nearly 20 days and missing the sales peak season.

Later,the company entrusted Zhongshen to act as its agent.Ms.Mai assisted in translating and notarizing the CSR,and connected with a third-party testing agency to supplement the safety report for the active ingredient (proving that it meets the safety limits specified in China’s regulations); Mr.Zhuang accurately classified the commodity code and adjusted the tariff declaration; Mr.Wu communicated with the commodity inspection agency in advance to ensure smooth testing.Eventually,the batch of eye cream completed customs clearance in only 7 days,catching up with the Double 12 Shopping Festival that year and recovering some losses.

5.Common Problems and Solutions for French Cosmetics Import Customs Declaration

Common ProblemsZhongshen SolutionsRisks Avoided
EU CSR not translated into Chinese and notarized,or inconsistent with China’s regulationsAssist with translation and notarization,supplement China-specific risk assessment reportsCustoms declaration return,customs clearance delay
Raw material ingredients do not comply with China’s Cosmetics Safety Technical SpecificationsReview ingredient list in advance,recommend third-party testing agenciesCommodity inspection failure,product destruction
Incorrect commodity code classificationAccurate classification based on ingredients and efficacy,verify tariff ratesOverpayment of tariffs,customs inquiries
Labels do not comply with China’s Cosmetic Label Management MeasuresReview labels in advance,adjust ingredient order and efficacy claimsLabel rectification,customs clearance delay
Risk of failed microbial/heavy metal testingPre-test before shipping,early communication with commodity inspection agenciesSampling failure,sales delay

6.Zhongshen’s Value: Balancing Efficiency and Compliance

For enterprises importing French cosmetics,customs clearance efficiency directly affects the sales rhythm,while compliance is related to the survival of the enterprise.Zhongshen helps clients through services such as pre-advance review,professional classification and commodity inspection follow-up:

  • Shortencustomsclearancecycle:Onaverage3-5daysfasterthantheindustryaverage
  • Reducecompliancerisks:ThecompliancerateofFrenchcosmeticsimportbusinessagentedinthepast3yearshasreached100%
  • Savecosts:Throughaccurateclassification,helpclientssaveanaverageof5%-8%oftariffcosts

As Mr.Fan,General Manager of Zhongshen,said: "The core of importing French cosmetics is not ’following procedures’,but ’understanding the rules’.Our 20 years of experience is to turn complex rules into simple operations for our clients,so that they can focus on the market without worrying about customs clearance."

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