The principle underlying European Cosmetics Regulation 1223/2009 is that it is to be directly applied and identical in the 31 countries of the European Economic Area. But does everyone really share the same rules and obligations? It is still far from being the case, as was shown during the afternoon of conferences the FEBEA (France’s Federation of Beauty Companies) dedicated to the issue last April 13, 2015.
With its Decrees of application and “supplementary” Orders, France is not the only one to occasionally take some liberties with the theory of equality for all players when it comes to enforcing the Cosmetics Regulation. It has been almost two years since it came into force, and some of its provisions present a few variations in other Member States as well. Isabelle Martin, who has been taking part in Cosmetics Europe working groups as Estée Lauder’s Director of European External Affairs, presented the reports on the problems encountered in several European countries. She specified from the start that if there are difficulties indeed, the situation is not catastrophic.
Times are hard for importers
A ‘specific regime’ was already applied on imports from countries outside Europe in Greece, Italy, Spain, and Portugal when the Cosmetics Directive was in force. Then, a few modifications were made with the advent of the Regulation, but imports are still subject to distinct rules in these countries, in particular with very specific requirements and inspections at the customs.
In Greece and Italy
The product’s notification number in the European portal is systematically required for it to be imported, although the notification was not designed to be …
