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Cosmetics export in 2026: market opportunities and compliance requirements to grow abroad

Cosmetics export in 2026: market opportunities and compliance requirements to grow abroad

TLDR
  • According to Cosmetica Italia, the Italian cosmetics industry is worth 16.5 billion euros and exports nearly 8 billion, an increase of 12% over the previous year, equivalent to 47.9% of the production.
  • Regulation (EC) 1223/2009 is the baseline for compliance: it requires a Responsible Person, a Product Information File (PIF), and notification through the CPNP portal.
  • The Certificate of Free Sale, issued in accordance with the procedure of the Ministry of Health, enables registrations, notifications and customs checks in countries outside the EU, but does not replace local requirements.
  • Each market has its own rules: the United Kingdom with SCPN, the USA with MoCRA, China with CSAR, the Gulf with GSO 1943/2016, ASEAN with notification and PIF, India with CDSCO registration.
  • Export is managed in phases: market selection, compliance verification, entry strategy, and post-market monitoring, integrating commercial and regulatory aspects.
Index

Cosmetics export: opportunities and operational implications 

The growing global demand for quality cosmetic products makes cosmetics export a strategic lever for many Italian companies. In particular, consumers in many emerging economies and mature markets are showing increasing interest in skincare, haircare and dermocosmetic products characterized by high quality standards, natural ingredients and strong brand identity. 

At the same time, the industry is characterized by a strong regulation international. Indeed, each country or economic area has specific requirements for product safety, labeling, technical documentation, and economic operator responsibility. Accordingly, the export of cosmetics cannot be handled solely as an extension of domestic sales activities, but must be approached as a true internationalization project. On the one hand, it is necessary to carefully analyze the potential of the target markets, assessing demand size, distribution channels, competitive dynamics, and brand positioning. On the other hand, it is essential to verify the compliance of products with local regulations, preparing the required technical documentation and adapting formulations, labeling and claims if necessary. Only through structured planning is it possible to reduce operational risks and turn internationalization into a concrete lever of competitive development. 

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The starting point: Europe as the “baseline” of compliance 

For Italian companies, EU compliance is often the most solid base from which to start, because the Regulation (EC) 1223/2009 defines a complete facility: accountability, safety, labeling, documentation, and post-market surveillance.  

In operational summary, to sell a cosmetic in the EU, it is necessary: 

  • identify a Responsible Person that ensures the product's compliance throughout its life cycle;  
  • set up and maintain a Product Information File (PIF), with safety assessment and updated technical documentation;  
  • make the notification via CPNP, the European cosmetics notification portal (once notified, no further national notification is needed).  

This basis is also important because many non-EU countries, while having their own rules, adopt “related” logics (product dossier, notification/registration, label requirements, safety requirements).

Export documentation: the role of the Certificate of Free Sale (CLV) 

When exporting outside the European Union, it is common for the importer or local authority to require a Certificate of Free Sale (CLV): is a document certifying that the product is legally marketed in the country of origin and is often used as a “documentary basis” for marketing abroad. The Ministry of Health regulates the procedure for issuing CLVs for the export of cosmetics, including the forms and elements required for the application. In practice, the CLV does not replace the requirements of the country of destination, but enables them: is often one of the key documents to initiate customs registrations, notifications or audits. 

Good manufacturing practices: GMP and ISO 22716 as reference standards 

On the production side, many authorities and trading partners (distributors, retailers, private labels) require evidence of a system GMP. In the cosmetics industry, the gold standard is. ISO 22716, which provides guidelines for production, control, storage and shipment of cosmetics. In 2026, even when certification is not formally mandatory, the presence of sound and documented GMP procedures is often a competitive advantage because it accelerates two crucial steps: supplier qualification and “holding” in case of checks or audits. 

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Non-EU countries: what really changes and why an area strategy is needed 

United Kingdom: separate post-Brexit compliance. 

The UK requires separate management from the EU: there is a need for a Responsible Person established in the United Kingdom and product notification through the UK Notification Service (SCPN). Operationally, this impacts label (RP data), traceability, and document management, especially when working in parallel across the EU and UK. 

U.S.: MoCRA and strengthening obligations 

In the U.S., the most relevant development in 2026 is the implementation of the Modernization of Cosmetics Regulation Act (MoCRA), which significantly expands the FDA regulatory levers. FDA provides, among other things, registration of facilities (with two-year renewal) and product listing (with annual updates), as well as requirements to report serious adverse events within defined time frames. For one exporter, this means that the’US market entry requires more structured oversight today: correct labeling is not enough, we need an accountability and traceability framework consistent with MoCRA obligations. 

China: CSAR and safety assessment requirements 

China remains a high-potential but regulatively challenging market. As the framework evolves CSAR, authorities have strengthened the approach based on safety assessment; industry sources indicate the introduction of the requirement to full safety assessment for marketed cosmetics, with specific timelines for entry into force. For many companies, this involves advance work on dossiers, ingredients, claims and technical documentation. 

Middle East: technical standards and local requirements 

In the Gulf countries, compliance is often anchored in common technical standards, with requirements on safety and claims (e.g., references such as GSO 1943/2016 and related standards), but with procedures and authorities that may vary at the country level. Concretely: the same formula may be acceptable, but change language/label structure, records, documentary requirements, and timing. 

ASEAN: notification and BIPs as the underlying rationale 

In several ASEAN countries an approach based on notification of the product and preparation of a Product Information File To be made available to the authorities. For European brands, it is a “family” model (dossier + notification), but it requires point adaptations On labeling and document management. 

India: registration of imported cosmetics 

In India, to import cosmetics is required to register according to the Cosmetics Rules, 2020 at the competent authority (CDSCO), with evidence that no cosmetics can be imported without registration. This is something that should be considered from the start of the export project because it impacts importer selection and market entry timelines. 

A solid methodology for growing abroad in 2026 

In the cosmetics industry, the’entry into international markets cannot be managed episodically: in 2026, the companies that grow in cosmetics exports are those that adopt a phased internationalization path, in which commercial and regulatory aspects are managed in an integrated way. 

  1. The first step concerns the selection of priority markets. Not all countries have the same potential for a specific brand or product category. Therefore, it is crucial to analyze indicators such as market size, growth rates, distribution channel structure, competitor positioning, and local consumer preferences. At this stage, it is important to understand whether the product fits into a premium, dermocosmetic, natural, or mass market segment, and to identify the markets where such positioning may be most competitive. 
  1. Once the target markets have been identified, the next step is to regulatory compliance assessment. Indeed, each country has specific requirements for product safety, registration, technical documentation, and legal liability. In many cases, it is necessary to verify the compliance of ingredients with local positive and negative lists, adapt labeling to language regulations, and prepare technical dossiers that comply with the requirements of control authorities. A central element of this phase is the preparation of the technical and regulatory documentation. Key documents required include the Product Information File (PIF), product safety reports, any Good Manufacturing Practices (GMP) certifications, and documents such as the Certificate of Free Sale. Accurate management of this documentation helps expedite registration processes and reduce the risk of customs blockages or challenges from local authorities. 
  1. Next, the company must define a market entry strategy, which can involve different operating models. Some companies choose to partner with local distributors, who are familiar with the country's regulatory and business environment; others prefer to develop a direct presence through sales branches or e-commerce platforms. The choice depends on various factors, including the size of the investment, the complexity of the market, and the desired level of control over distribution. 

Finally, it is essential to provide a system of post-market monitoring and management. Even after products are placed on the market, companies must ensure product traceability, handle any safety alerts and keep technical documentation up to date. This has become particularly relevant in recent years as many regulatory authorities are strengthening surveillance systems and controls on imported cosmetics. 

Conclusions 

In 2026 the export of cosmetics is a concrete and measurable opportunity, as shown by Italian industry trends and global market growth. At the same time, it is an industry where the speed of expansion depends on the ability to properly manage rules, responsibilities and documents in target markets. For companies that aspire to grow in a structured way, compliance is not a cost “to suffer,” but a competitive lever: it reduces risk, accelerates channel access, and strengthens credibility with partners and consumers. 

For a concise overview of the main certifications and documents required for cosmetics export (CLV, GMP, FDA, EAC, etc.), you can also read our in-depth article: Export cosmetics: certifications and opportunities for the foreign market. 

Frequently Asked Questions

What requirements are required to sell a cosmetic product in the European Union according to Regulation 1223/2009?

To sell a cosmetic product in the EU, Regulation (EC) 1223/2009 requires three elements: a Responsible Person who guarantees compliance throughout the product’s life cycle, a Product Information File (PIF) with safety assessment and updated documentation, and notification on the CPNP portal. After the CPNP notification, no further national notification is required.

What is the Certificate of Free Sale (CLV) for exporting cosmetics outside the EU?

The CLV certifies that the cosmetic is legally marketed in the country of origin and is often requested by importers or local authorities as documentation. It does not replace the obligations of the country of destination, but enables them, for example for registrations, notifications, or customs checks. In Italy, the procedure for issuing cosmetics is regulated by the Ministry of Health.

Are ISO 22716 and GMP certification mandatory for exporting cosmetic products?

ISO 22716 certification is not always formally mandatory, but it is the benchmark standard for good manufacturing practices (GMP) in cosmetics, with guidelines on production, control, storage, and shipment. Distributors, retailers, and private label customers often require proof of compliance. Documented GMP procedures accelerate supplier qualification and help in the event of inspections or audits.

What changes does the MoCRA bring to exporting cosmetics to the United States?

With the Modernization of Cosmetics Regulation Act (MoCRA), the FDA has expanded its powers: facilities are required to be registered with biennial renewal, product listings are updated annually, and serious adverse events must be reported within specified timeframes. For exporters to the USA, a proper labeling is no longer sufficient; a system of accountability and traceability must be in place in line with these obligations.

How does the registration of cosmetics imported into India work?

In India, no cosmetic product can be imported without registration under the Cosmetics Rules, 2020, with the competent authority CDSCO. Therefore, it must be considered from the outset of the export project, as it affects the choice of importer and the time of entry into the market. Other markets, such as the ASEAN countries, rely on product notification and PIF instead.

What are the steps for building a structured cosmetics export project?

A cosmetic export project is divided into four phases: selection of priority markets based on size, growth, channels and competition; assessment of regulatory compliance with PIF, safety reports, GMP and CLV; choice of the entry model, between distributors, branches or e-commerce; post-market monitoring with traceability, safety reports and updated documentation.

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