French importers sourcing gel polish from China must navigate EU cosmetic regulations for gel polish (Regulation EC No 1223/2009). Key obligations include ingredient restrictions, CPSR safety assessments, appointing an EU Responsible Person, CPNP notification, PIF maintenance, and mandatory French labeling.
As a professional gel nail polish manufacturer in China, YouGel provides OEM/ODM solutions, including HEMA-free and TPO-free formulations, to support international buyers in developing products for the European market.
What EU Cosmetic Regulations Apply to Gel Polish Imported into France?
The primary legal framework is Regulation (EC) No 1223/2009, which establishes safety, ingredient, manufacturing, documentation, and labeling requirements for cosmetic products throughout the European Union.
For French importers, understanding EU cosmetic regulations for gel polish is essential because products manufactured outside the EU must meet the same requirements as products made within Europe.
Key regulatory obligations include:
| Regulatory Requirement | What Importers Must Check |
|---|---|
| Ingredient compliance | No prohibited ingredients; restricted ingredients meet applicable conditions |
| Product safety | A completed Cosmetic Product Safety Report (CPSR) |
| Responsible Person | An appointed legal entity or individual established in the EU |
| Product Information File | Complete and accessible product documentation |
| CPNP notification | Notification before placing products on the EU market |
| GMP | Manufacturing follows Good Manufacturing Practice |
| Product labeling | Mandatory information and French-language requirements |
Under Article 8, cosmetic manufacturing must comply with Good Manufacturing Practice (GMP). ISO 22716 is the relevant harmonized standard commonly used to demonstrate GMP compliance.
Are TPO and HEMA Allowed in Gel Polish Sold in France?
TPO is prohibited in EU cosmetic products from September 1, 2025, while HEMA and DI-HEMA Trimethylhexyl Dicarbamate are restricted to professional-use nail products with mandatory warnings. French importers must verify both ingredients against current EU requirements.
TPO restrictions
Commission Regulation (EU) 2025/877 added TPO (Trimethylbenzoyl Diphenylphosphine Oxide, CAS 75980-60-8) to the prohibited substances list under Annex II of the Cosmetics Regulation.
The prohibition has been in effect since September 1, 2025. It covers both placing products on the market and making them available commercially, including existing stock. There is no sell-through exemption for products containing TPO.
HEMA restrictions
HEMA (2-Hydroxyethyl Methacrylate) and DI-HEMA Trimethylhexyl Dicarbamate are listed in Annex III.
Their use in nail products is restricted to professional use, with the following mandatory warnings:
- For professional use only.
- Can cause an allergic reaction.
Importers should distinguish between these requirements:
| Ingredient | EU Regulatory Status | Importer Action |
|---|---|---|
| TPO | Prohibited in cosmetics | Verify that the formula contains no TPO |
| HEMA | Restricted to professional-use nail products | Check intended users and mandatory warnings |
| DI-HEMA Trimethylhexyl Dicarbamate | Restricted to professional-use nail products | Check conditions and mandatory warnings |
Choosing HEMA-free and TPO-free formulations can help buyers develop product lines suited to their target market. However, these claims do not automatically establish full EU compliance. All ingredients must still satisfy applicable restrictions and safety requirements.
Which Compliance Documents Are Required Before Importing Gel Polish?
French importers must ensure that each cosmetic product has a completed safety assessment, an accessible Product Information File, and a CPNP notification before it is placed on the EU market.
The three most important compliance elements are:
1. Cosmetic Product Safety Report (CPSR)
The CPSR evaluates whether a finished cosmetic product is safe under normal and reasonably foreseeable conditions of use.
It includes two parts:
- Part A: Cosmetic Product Safety Information.
- Part B: Cosmetic Product Safety Assessment completed by a qualified safety assessor.
2. Product Information File (PIF)
The PIF contains essential product information, including:
- Product description and identification.
- CPSR.
- Manufacturing method and GMP compliance statement.
- Evidence supporting product claims, where applicable.
- Relevant animal testing information.
The Responsible Person must keep the PIF accessible for 10 years after the last batch was placed on the market.
3. Cosmetic Products Notification Portal (CPNP)
The Responsible Person must notify the product through the EU’s online CPNP system before market placement.
CPNP notification is free and does not constitute EU approval or certification. Once a product has been notified, separate national product notification is generally unnecessary within the EU.
| Document | Main Purpose | Responsible Party |
|---|---|---|
| CPSR | Demonstrates product safety | Responsible Person and qualified safety assessor |
| PIF | Stores compliance and product information | Responsible Person |
| CPNP | Notifies EU authorities of the product | Responsible Person |
What Labeling Requirements Must Gel Polish Meet in France?
Gel polish sold in France must display the mandatory information required by Article 19 of the EU Cosmetics Regulation, with the applicable consumer-facing information provided in French.
Importers should check the following details before approving packaging:
- Name and address of the EU Responsible Person.
- Country of origin for products manufactured outside the EU.
- Nominal content, such as 15 ml.
- Date of minimum durability or period-after-opening indication, as applicable.
- Precautions for use and required warnings.
- Batch number or manufacturing reference.
- Product function, unless clear from its presentation.
- Full ingredient list using INCI nomenclature.
French-language requirements are particularly important for precautions, warnings, and other information specified under Article 19(5).
For example, a professional-use gel polish containing HEMA must carry the required professional-use and allergy warnings. Translating only the product name while leaving mandatory safety information in English is insufficient.
How Can French Importers Choose a Compliant Gel Polish Manufacturer in China?
A reliable gel polish manufacturer in China should provide accurate formulation information, traceable production records, relevant technical documents, and consistent communication throughout the product development process.
Before placing a wholesale order, follow these five steps:
- Verify ingredient information: Request the complete qualitative and quantitative formulation information needed for regulatory assessment. Confirm TPO status and check all restricted ingredients.
- Request technical documentation: Ask for INCI lists, raw material specifications, safety-related data, and available manufacturing quality documents.
- Confirm formulation suitability: Ensure the intended product use, professional or consumer positioning, and warnings match the applicable EU restrictions.
- Check manufacturing quality: Review GMP practices, production controls, batch records, and quality inspection procedures.
- Clarify compliance responsibilities: Agree on who will arrange the CPSR, maintain the PIF, submit the CPNP notification, and approve French labeling.
An additional purchasing consideration: verify compliance at the shade and formula-version level.
A gel polish collection may contain dozens or hundreds of colors, but different pigments and formulation changes can affect ingredient compliance and safety assessment. Importers should request a shade-level ingredient mapping and formulation revision record rather than relying on one general product specification for an entire collection.
This approach makes quality control, regulatory updates, and future product replenishment easier to manage.
What Should French Importers Check Before Placing a Wholesale Gel Polish Order?
A structured pre-order checklist helps reduce compliance risks and prevents costly packaging or formulation changes after production.
| Checklist Item | Verification |
|---|---|
| TPO-free formulation | Confirm through current ingredient documentation |
| HEMA restrictions | Check professional-use conditions and warnings |
| INCI ingredient list | Obtain accurate formulation information |
| CPSR | Confirm completion before market placement |
| PIF | Confirm availability and EU accessibility |
| CPNP | Confirm notification before market placement |
| French labeling | Approve all mandatory translated information |
| Batch traceability | Confirm batch identification and records |
| Formula consistency | Document formula versions and changes |
Following this checklist helps importers manage gel polish EU compliance before committing to large-volume orders.
Frequently Asked Questions
1. Is TPO-free gel polish mandatory in France?
Yes. TPO is prohibited in all cosmetic products placed or made available on the EU market from September 1, 2025. This includes gel polish sold in France.
2. Does gel polish need CPNP notification before entering France?
CPNP notification must be completed before the cosmetic product is placed on the EU market. It is not an import permit or product certification.
3. Who is responsible for EU cosmetic compliance when importing from China?
The importer is generally the Responsible Person for the specific imported product. However, the importer may appoint another EU-established person through a written mandate, provided that person accepts the role in writing.
4. Can HEMA-free gel polish be sold to French consumers?
HEMA-free formulations avoid the specific HEMA restriction, but the finished product must still satisfy all other applicable EU cosmetic safety, ingredient, documentation, and labeling requirements.
5. Can a Chinese gel polish manufacturer provide EU compliance support?
Yes. Manufacturers can provide formulation details, INCI lists, technical data, and production documentation to support the importer and EU Responsible Person. However, regulatory responsibility and formal safety assessment must be handled by the appropriate legally designated parties.
Conclusion
Understanding EU cosmetic regulations for gel polish is essential for French importers sourcing products from China. Ingredient restrictions, CPSR, PIF, CPNP notification, Responsible Person designation, and French labeling must all be addressed before products enter the market.
As a leading gel nail polish manufacturer in China, YouGel provides premium OEM/ODM services with 10,000+ gel shades, including HEMA-free, TPO-free, Vegan, and Cruelty-free options. We continuously innovate to deliver high-quality, trend-driven products at competitive prices. Whether you are a French importer, wholesaler, distributor, or private label brand, YouGel is ready to support your product development and bulk sourcing needs. Contact YouGel today to discuss your gel polish requirements and build your next collection for the European market.
