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Business 9 min read

Exporting Fragrance Raw Materials into the EU

REACH registration, SDS, CLP labelling and the paperwork a European buyer will ask for before the first order.

REACH is the entry requirement

Any substance manufactured or imported into the EU in quantities of one tonne or more per year needs a REACH registration, either by the manufacturer or by an EU-only representative. Ask your supplier for the registration evidence covering the substance you are buying.

The SDS is not optional

A safety data sheet conforming to the REACH format is required for any substance supplied to a professional buyer in the EU. An SDS that is older than the current format revision is a finding in an audit, so check the revision date.

CLP classification decides the label

CLP (Regulation 1272/2008) governs how the substance is classified and labelled. Look for the hazard statements in section 2 of the SDS and confirm the classification matches how the material is actually offered to you.

EU 1223/2009 applies to the finished cosmetic

If your customer sells cosmetics in the EU, their obligation runs to Annex III allergen declaration. That is their responsibility, but they will ask you which materials in your product are named allergens and at what concentrations - so the material data you supply should support that calculation.

Agree the Incoterm before the goods move

EXW, FOB, CIF and DDP carry very different cost and risk profiles, and freight from China to the EU can be a significant part of the landed cost. State the Incoterm in the quotation rather than working it out afterwards.