Selling Cosmetics in Germany: The Complete 2026 Checklist

Why Germany, and why now

Germany is Europe's largest beauty market by a clear margin. Selective beauty alone, which is the prestige segment sold through perfumeries and department stores, reached 2.45 billion euros between January and August 2026, up 0.8 percent on the previous year according to the industry association VKE and Circana. The mass channel is bigger still. dm, Rossmann and Müller run more than 4,000 drugstores between them, and they are listing more international and Asian brands every season.

At the same time, Germany is the market where a missing document ends a buyer conversation. German buyers check paperwork before they check your brand story. That is not hostility. It is how they protect themselves, because the retailer carries the liability on the shelf. So the order of work is fixed: compliance first, retail second.

Step 1. Know which law applies

In Germany and Austria, cosmetics are governed directly by Regulation (EC) No 1223/2009. It is an EU regulation, so it applies word for word in every member state. Germany adds national rules through the Kosmetik-Verordnung, mainly on language and enforcement. Switzerland is not in the EU. It has its own ordinance on cosmetic products, which follows the EU text closely but is enforced separately.

One consequence matters for UK, US and Asian brands: a product that is compliant in the UK, the US or Korea is not automatically compliant in the EU. The ingredient annexes, the safety assessment format and the labelling rules differ. Check the formula first, then the pack.

Step 2. Appoint an EU Responsible Person

Article 4 of the regulation requires a Responsible Person for every cosmetic product placed on the EU market. This person or company must have an address in the EU. They guarantee compliance, keep the Product Information File, handle the CPNP notification and are the contact for the authorities.

Who can take the role:

• Your own EU subsidiary, if you have one.
• Your importer or distributor, who becomes the Responsible Person by law when they import, unless you mandate someone else in writing.
• A regulatory service provider, under a written mandate.

For UK brands this is the first thing that changed after Brexit. A UK Responsible Person is still required for the UK market, but it does not count in the EU. Many brands now run two files in parallel, one for each side.

A practical note. If your distributor is your Responsible Person, your compliance depends on that relationship. When the distributor changes, the RP changes, and so does the address on every pack. Brands that plan to work with several partners in DACH usually prefer a neutral Responsible Person from the start.

Full guide: EU Responsible Person for Cosmetics: What UK and Non-EU Brands Need to Know.

Step 3. Build the Product Information File and the safety report

Before a product is sold, the Responsible Person must hold a Product Information File, the PIF, at their EU address and keep it for ten years after the last batch. The PIF contains the product description, the Cosmetic Product Safety Report, the manufacturing method with a statement of Good Manufacturing Practice, proof of the claimed effects, and data on animal testing.

The Cosmetic Product Safety Report, the CPSR, is the heart of the file. It has two parts. Part A collects the safety information: formula, toxicological profile of each ingredient, exposure, stability, microbiological quality, packaging compatibility. Part B is the assessment, signed by a qualified safety assessor with a degree in pharmacy, toxicology, medicine or a similar discipline recognised in the EU.

If your products already have a CPSR for the UK, ask the assessor whether it was written against the EU annexes. The two rule books started identical in 2021 and have drifted since, on ingredients such as retinol, certain UV filters and fragrance allergens.

Step 4. Notify the product in the CPNP

The Cosmetic Products Notification Portal, the CPNP, is the EU database where every product is registered before it is placed on the market. The notification is free. It is done by the Responsible Person and includes the product name, category, the frame formulation or full formula, the label, the photo of the pack and the country of origin for imported products. Nanomaterials have a separate, earlier notification.

A notification does not mean approval. Nobody in Brussels reviews it. It means the authorities can find your file when they need it. The German enforcement bodies are the federal states, and they do use the portal.

Full guide: CPSR, PIF and CPNP: The Three Documents Behind Every Cosmetic Sold in the EU.

Step 5. Put the label into German

This is the step most brands underestimate. Article 19 of the regulation lists the mandatory particulars. Germany's Kosmetik-Verordnung, section 4, requires the following to appear in German:

• The function of the product, unless it is obvious from the presentation.
• The precautions for use and the warnings from the annexes.
• The nominal content at the time of packing, in grams or millilitres.
• The date of minimum durability, or the period after opening symbol with the months.
• The batch number.

The ingredient list stays in INCI and does not need translation. The name and EU address of the Responsible Person go on the pack. Imported products carry the country of origin. A permanent, legible sticker is legal, but German buyers read a sticker as a test run. Printed packs signal that you are serious about the market.

Two 2026 changes affect the label directly. Since 31 July 2026, products placed on the market must declare the extended list of fragrance allergens under Regulation (EU) 2023/1545. For most products that means 80 allergens instead of 26, each listed individually above the threshold. Products already on the market have until 31 July 2028. And since 27 September 2026 Germany applies the EU rules on environmental claims, see step 6.

Full guide: Cosmetic Labelling in Germany: What Must Be on the Pack, and in Which Language.

Step 6. Check every claim against the 2026 rules

Claims on cosmetics have always been regulated through Regulation (EU) No 655/2013 and its common criteria. The claim must be true, provable, honest and fair. In Germany, "clinically proven" without a clinical study and "dermatologist tested" without a dermatologist are classic reasons for a competitor's warning letter, the Abmahnung, which arrives with a bill.

The bigger change is new. Since 27 September 2026 the EU Empowering Consumers Directive is in force in Germany through the Unfair Competition Act, the UWG. Three things are now prohibited:

• Generic environmental claims such as "eco-friendly", "green" or "climate neutral" without recognised, demonstrable excellence behind them.
• Sustainability labels that are not based on a certification scheme or established by a public authority. COSMOS, Natrue and comparable schemes qualify. A self-made leaf icon does not.
• Claims about the whole brand or range when only some products meet the standard.

For packaging already printed before the change, section 15b UWG allows a sell-off until 27 September 2028. New artwork has to comply now. If your home market is the UK or the US, assume that half of your sustainability wording needs a rewrite for the German pack and website.

Step 7. Register your packaging before the first sale

Germany has a duty that catches almost every foreign brand. Under the Packaging Act, the VerpackG, anyone who places packaged goods on the German market for the first time, including a brand shipping from abroad, must register in the LUCID packaging register of the Zentrale Stelle Verpackungsregister and join a licensed dual system that pays for collection and recycling. Registration comes before the first unit is sold, not after. Online marketplaces have to check your LUCID number and will block listings without it.

Austria has a separate licensing duty through its collection schemes, and from 1 October 2026 a parcel tax of 2 euros per parcel on mail order, which only large sellers and platforms with more than 100 million euros of Austrian revenue pay directly. Across the EU, the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026 and will tighten the rules on minimum recyclability and empty space over the coming years.

Full guide: LUCID and the German Packaging Act: What Foreign Beauty Brands Must Do.

Step 8. Watch the formulation deadlines for 2026 and 2027

Compliance is not a one-off. These are the dates we currently track for brands entering Germany:

Microplastics restrictions under Regulation (EU) 2023/2055 phase in over several years and already cover glitter and microbeads. An EU draft currently in the Council would add new bans to Annex II from 1 February 2027. Reformulations usually need a new CPSR and a new CPNP notification, so the earlier you know, the cheaper it is.

Step 9. Know your landed cost, because it changed in 2026

For skincare and make-up under HS heading 3304, the EU customs duty is 0 percent. For years that made direct shipping from the UK, the US or Korea the easy first step into Germany. Three new charges have changed the maths.

• 1 July 2026. The 150 euro duty exemption is gone. The German customs authority confirmed a flat duty of 3 euros per item on low-value consignments until 1 July 2028. For cosmetics that is a completely new cost, not a simplified old one.
• 1 October 2026. Austrian parcel tax of 2 euros per parcel, paid by large sellers and platforms.
• 1 November 2026, expected. EU handling fee of 2 euros per item, part of the customs reform approved by the Council on 3 September 2026.

"Per item" means per customs line, not per parcel. An order with a cleanser, a serum and a cream is three lines. Add import VAT of 19 percent in Germany, 20 percent in Austria and 8.1 percent in Switzerland, and the carrier's brokerage fee. On a 45 euro order the new charges alone can take more than 10 percent of the revenue.

The alternatives are the classic ones, and each has a different compliance profile. Importing in bulk into EU stock pays duty once at 0 percent and avoids the per-item charges on later sales. A distributor imports under their own Responsible Person and takes the margin. A retailer who imports directly is the most attractive route and the slowest to build. None of them is right for every brand. The point is to calculate before you decide.

Full guide: Landed Cost for Cosmetics in Germany: Duty, VAT and the New Per-Item Charges.

Step 10. Choose the channel before you choose the retailer

Germany does not have one beauty retailer. It has five systems, and they rarely overlap.

The first question a German buyer asks is not "what makes your brand special". It is "is your file complete". The second is "who else in Germany sells you". Answer the first before you approach anyone, and think carefully about the second, because an early listing with the wrong partner can close the door to the right one.

Full guide: Who Sells Beauty in Germany? The Retail Map for Brands.

Austria and Switzerland in short

Austria applies the same EU regulation and also requires German on the label. Add Austrian packaging licensing, the parcel tax for large sellers from October 2026, and 20 percent VAT. The retail landscape is smaller and more concentrated: dm, Bipa and Müller in drugstore, Douglas and Marionnaud in perfumery.

Switzerland is outside the EU and outside the customs union. There is no CPNP notification. The Swiss ordinance on cosmetic products mirrors the EU rules and the Federal Food Safety and Veterinary Office adopts most EU ingredient changes with a delay. The pack must show the name and address of a responsible person based in Switzerland, usually your importer, and the mandatory particulars appear in at least one official language, in practice German for most of the country and French for Romandy. VAT is 8.1 percent. Retail runs through Manor, Globus, Coop, Migros, Douglas and the Swiss pharmacy chains.

The checklist

• Formula checked against the EU annexes, including the 2026 and 2027 deadlines
• EU Responsible Person appointed, with a written mandate
• Product Information File complete, CPSR Part A and Part B signed by an EU-recognised assessor
• CPNP notification submitted for every product and variant
• Label in German: function, precautions, content, durability or PAO, batch, RP address, country of origin
• Fragrance allergens declared under Regulation (EU) 2023/1545
• Every claim checked against Regulation (EU) No 655/2013 and the UWG rules on environmental claims
• LUCID registration and dual system contract in Germany, packaging licence in Austria
• Landed cost calculated per unit, including the 2026 per-item charges and VAT
• Channel decided: direct, EU stock, distributor or retailer import
• Retailer shortlist that matches the price point and the channel
• German product pages, customer service and returns address ready before launch

Questions brands ask us

Tity Sonko

Founder and Managing Director of SONKO Consulting GmbH in Leverkusen, Germany. Tity works with international prestige beauty brands on their entry into Germany, Austria and Switzerland, from the first compliance check to the first retail order. She writes the weekly newsletter The DACH Prestige Signal.