SOP for Compliance in Importing Products into European Countries

Common Compliance Requirements：

To ensure compliance with cross-border warehousing and inbound order processes, the core compliance requirements are specified as follows:

Currently, there are 5 VAT warehouses: UK warehouses, Germany warehouses, France warehouses, Vietnam warehouses, and Switzerland warehouses; when creating a Inbound order, an importer must be bound. （Cirro-Product-Importers）
Customs clearance documents:

– UK Warehouse: If the registered country is the UK, no customs clearance documents are required for review; if the registered country is not the UK, customs clearance documents must be submitted for review.

– Germany Warehouse: Regardless of whether the registered country is an EU member state or not, customs clearance documents must be submitted for review.

– France Warehouse: If the registered country is an EU member state, no customs clearance documents are required for review; if the registered country is not an EU member state, customs clearance documents must be submitted for review.

Tax Number: For the UK, a UK-specific customs tax number starting with “GB” must be used (EORI);

for EU countries, a general EU tax number is sufficient.

Example: For imports into the UK from other locations, regardless of the country where the company is registered, it is required to provide VAT and EORI.

UK：

Beauty and Daily Chemicals

Common Products

– Talcum powder, soap, hair removal agents, deodorants, antiperspirants;

– Hair dyes, hair styling products, hair cleaning products, hair care products;

– Lip balms, oral and dental care products, nail care products, facial masks, shaving products (creams, foams, lotions), makeup and makeup remover products;

– Spermicides, enemas, lubricants (adult toys) with a volume of 50ml or more;

– Pet cosmetics, children’s cosmetics, etc.

Note: Perfumes, toilet water, colognes, and high-pressure sprays are not allowed to be stored.

Documents to be Submitted

– Product MSDS Report

– Screenshot of the SCPN Registration Certificate

Information on UK Cosmetics Requirements

– For more information on UK cosmetics requirements, please visit:

https://www.businesscompanion.info/en/quick-guides/product-safety/cosmetic-products.

– Starting from January 1, 2021, the revised version of EU Regulation 1223/2009 (https://www.legislation.gov.uk/eur/2009/1223/contents) has applied to cosmetics supplied and sold in England, Scotland, and Wales (“Great Britain”), known as the “Great Britain Cosmetics Regulation”.

– For cosmetics supplied or sold in Northern Ireland (“NI”), similar requirements apply, but the applicable regulation is the EU version of Regulation (https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009R1223) 1223/2009 (“EU Cosmetics Regulation”).

E – cigarette – related Products

Documents to be Submitted

– Provide Registration Certificate: TRPR

– Labels and Packaging: Product labels and packaging comply with regulatory standards, including information such as warnings if applicable;

– Requirements for product ingredients: ① Nicotine content does not exceed the standards of respective countries; ② No other pharmaceutical or prohibited ingredients (except nicotine) are contained.

Food

Documents to be Submitted

– Product packaging and labels: Must include the following information—① Product name, ② Name and address of the manufacturer/distributor, ③ Validity period/shelf life, ④ Net content and net weight of the product contained.

– Shelf – life management;

– For dietary supplements, a GMP certificate is required.

GMP is the abbreviation of Good Manufacturing Practice (i.e., good manufacturing practice).

In the UK, food supplements are regulated as food and subject to the provisions of general food law.

In Northern Ireland, EU food laws related to food supplements continue to apply, as specified in the Northern Ireland Protocol：https://www.gov.uk/government/publications/new-protocol-on-irelandnorthern-ireland-and-political-declaration.

For requirements related to dietary supplements, please refer to the official website link for details: https://www.food.gov.uk/business-guidance/food-supplements#revision-log.

Importing supplements: If you import supplements into the UK, you are legally responsible for all aspects of those goods, including composition, safety and labelling of the products.

Bateries

A battery refers to any source of electrical energy generated through direct chemical energy conversion, including rechargeable and non – rechargeable batteries.

Instructions for Supporting Batteries

If sold separately, they fall into this category;
If sold with a product, they are classified according to the main product and must meet the battery warehousing requirements.

Common Products

Power banks with a capacity less than 100Wh, mobile power supplies, laptop batteries, car emergency power supplies, hand warmers.

Documents to be Submitted

Storage is allowed under the following restrictions, and only self – delivery is permitted:

Lithium batteries, power:

① ≤ 100Wh: Storage is allowed in the UK, and no documents need to be provided;

② > 100Wh: Storage is not allowed.

Loose button batteries: Whether they are lithium batteries or not, storage is not allowed in the UK. Only those installed in devices can be stored.

Pet Supplies – Cat Litter

Documents to be Submitted

– MSDS report.

No special storage conditions are required, and it can be stored at room temperature in the warehouse.

UKCA and CE Labels

How can clients determine if their products require UKCA or CE labels?

– All products subject to CE regulation must bear the CE mark to be sold in the EU market. For a list of CE-regulated products, refer to the official link: https://ec.europa.eu/growth/single-market/ce-marking/manufacturers_en.

– The UK requires the UKCA label, and UKCA-regulated products are the same as those subject to CE regulation.

Currently, there is no mandatory requirement for clients to maintain CE/UKCA/GPSR labels. However, if your products enter the EU without GPSR information or enter the UK without UKCA information, local law enforcement authorities may deem them non-compliant with local regulations, leading to consequences such as entry refusal, detention, recall, destruction, or fines.

What does the client need to do in our system? Please refer to the following document:

(Cirro- Product- Product Compliance- GPSR/UKCA)

DE：

Beauty and Daily Chemicals

Common Products

– Talcum powder, soap, hair removal agents, deodorants, antiperspirants;

– Hair dyes, hair styling products, hair cleaning products, hair care products;

– Lip balms, oral and dental care products, nail care products, facial masks, shaving products (creams, foams, lotions), makeup and makeup remover products;

– Spermicides, enemas, lubricants (adult toys) with a volume of 50ml or more;

– Pet cosmetics, children’s cosmetics, etc.

Note: Perfumes, toilet water, colognes, and high-pressure sprays are not allowed to be stored.

Documents to be Submitted

– Product MSDS Report

Electrical and Electronic Products

Documents to be Submitted

WEEE Registration Certificate (maintained in CIRRO: EPR Management). For details, please refer to https://www.stiftung-ear.de/anleitungen/weee-registrierung-beantragen/

Batteries

A battery refers to any source of electrical energy generated through direct chemical energy conversion, including rechargeable and non – rechargeable batteries.

Instructions for Supporting Batteries

If sold separately, they fall into this category;
If sold with a product, they are classified according to the main product and must meet the battery warehousing requirements.

Common Products

Power banks with a capacity less than 100Wh, mobile power supplies, laptop batteries, car emergency power supplies, hand warmers.

Documents to be Submitted

Storage is allowed under the following restrictions, and only self – delivery is permitted:

Lithium batteries, power:

① ≤ 100Wh: Storage is allowed in the DE, and no documents need to be provided;

② > 100Wh: Storage is not allowed.

Pet Supplies – Cat Litter

Documents to be Submitted

– MSDS report.

No special storage conditions are required, and it can be stored at room temperature in the warehouse.

Chainsaws, petrol saws, circular saws, slotting machines

Documents to be Submitted

MD Certification

MD certification, full name Machinery Directive (MD) Certification, refers to the compliance certification based on the EU Machinery Directive.

For machinery exported to the European market, it is required to apply for CE certification, affix the CE mark, and comply with the MD Directive. The applicable regulation is the new Machinery Directive 2006/42/EC, a specialized directive for mechanical equipment in the EU.

The core purpose of MD certification is to ensure that mechanical equipment does not cause harm to users or people in the surrounding environment during use.

Through risk assessment and conformity assessment, it verifies that the design and production of mechanical equipment meet specific safety standards, thereby safeguarding the safety of users.

GPSR (General Product Safety Regulation)

It applies to most non-food consumer products entering and leaving the EU and Northern Ireland. Cirro will conduct regular product inspections and freeze products that do not meet regulatory requirements. The restricted products include second-hand goods, repaired goods, refurbished goods, and spare parts, with the following exceptions:

– Human or veterinary medicines;

– Food;

– Animal feed;

– Living plants and animals (including genetically modified organisms and genetically modified microorganisms for closed use, as well as plant and animal products directly related to the future reproduction of plants and animals);

– Animal by-products and derived products;

– Plant protection products (e.g., pesticides);

– Consumer transport or travel equipment, provided that the equipment is directly operated by the service provider within the scope of transportation services for consumers, rather than by consumers themselves;

– Aircraft;

– Antiques.

Please ensure your products are labeled with the GPSR-required information. Labels can be affixed to the product, product packaging, product parcels, or accompanying documents—either separately or on the same side of the product.

① Labels must be clearly visible and non-removable;

② The size of the GPSR label should be adjusted proportionally to the packaging size.

If you change the EU Economic Operator, you must:

Add the new Economic Operator’s information in the system and rebind the SKU;
Display the updated Economic Operator’s information on the label;
Update the Economic Operator’s information in the product images, documents, and labels linked to the SKU.

What does the client need to do in our system? Please refer to the following document:

(Cirro- Product- Product Compliance- GPSR/UKCA)

CZ/FR/IT/ES：

Beauty and Daily Chemicals

Common Products

– Talcum powder, soap, hair removal agents, deodorants, antiperspirants;

– Hair dyes, hair styling products, hair cleaning products, hair care products;

– Lip balms, oral and dental care products, nail care products, facial masks, shaving products (creams, foams, lotions), makeup and makeup remover products;

– Spermicides, enemas, lubricants (adult toys) with a volume of 50ml or more;

– Pet cosmetics, children’s cosmetics, etc.

Note: Perfumes, toilet water, colognes, and high-pressure sprays are not allowed to be stored.

Documents to be Submitted

– Product MSDS Report

Batteries

A battery refers to any source of electrical energy generated through direct chemical energy conversion, including rechargeable and non – rechargeable batteries.

Instructions for Supporting Batteries

If sold separately, they fall into this category;
If sold with a product, they are classified according to the main product and must meet the battery warehousing requirements.

Common Products

Power banks with a capacity less than 100Wh, mobile power supplies, laptop batteries, car emergency power supplies, hand warmers.

Documents to be Submitted

Storage is allowed under the following restrictions, and only self – delivery is permitted:

Lithium batteries, power:

① ≤ 100Wh: Storage is allowed in the CZ/FR/IT/ES, and no documents need to be provided;

② > 100Wh: Storage is not allowed.

Pet Supplies – Cat Litter

Documents to be Submitted

– MSDS report.

No special storage conditions are required, and it can be stored at room temperature in the warehouse.

GPSR (General Product Safety Regulation)

It applies to most non-food consumer goods entering and leaving the EU and Northern Ireland. Cirro will conduct regular product inspections and freeze products that do not meet regulatory requirements. The restricted products include second-hand goods, repaired goods, refurbished goods, and spare parts, with the following exceptions:

– Human or veterinary medicines;

– Food;

– Animal feed;

– Animal by-products and derived products;

– Plant protection products (e.g., pesticides);

– Aircraft;

– Antiques.

① Labels must be clearly visible and non-removable;

② The size of the EU representative label should be adjusted proportionally to the packaging size.

If you change the EU responsible person, you must:

Add the new responsible person’s information in the system and rebind the SKU;
Display the updated responsible person’s information on the label;
Update the responsible person’s information in the product images, documents, and labels linked to the SKU.

What does the client need to do in our system? Please refer to the following document:

(Cirro- Product- Product Compliance- GPSR/UKCA)