What Documents to Ask a Supplier For Before You Stock

28 August 2026 · The Glow Trade

You ask a new Korean supplier for documentation and a PDF pack lands before lunch: a business registration, an ISO certificate for the factory, a certificate of authenticity with a gold seal on it. None of that tells you whether the goods on the quote can legally sit on a shelf in Europe.

The certificate is the weakest sheet in the file. No authority issues it, no register records it, no line of EU cosmetics law gives it standing, and anyone with a printer makes one in five minutes. Buyers ask for it most weeks, then skip the two documents that would have protected them.

The short version

Article 19(1)(a) of Regulation (EC) No 1223/2009 requires the responsible person's name and address to appear on the cosmetics packaging itself, not only on a certificate.
Article 70 of the Union Customs Code defines the customs value as the price actually paid or payable, so an invoice quoting a different figure is a customs violation.
Article 7 of Regulation (EC) No 1223/2009 and Article 51 of the Union Customs Code both require batch and supplier records to be kept for three years after the goods arrive.

The six requests, and what a straight answer looks like

Send all six at once, per order, before money moves. A supplier who already sells into Europe has five within reach.

1. Evidence of CPNP notification. Ask for the legal name and address of the EU responsible person and the CPNP product reference, per SKU, in writing. A good answer names one entity and repeats the address you will later read on the box. An evasive answer is "all our products are CPNP registered" with nobody named behind it. You cannot check the reference yourself: the Commission states the portal is open to competent authorities, poison centres, responsible persons and distributors and nobody else. Ask anyway, because it forces out a name you can match against the pack, and that match is as far as verification goes for a buyer.

2. A photograph of the responsible person on the pack. The back and the base of one real unit from the lot you would receive. Article 19(1)(a) of Regulation (EC) No 1223/2009 requires the responsible person's name and address on the container and the packaging, with the country of origin stated for imports. A good answer arrives the same day, legible, with an EU address. An evasive answer is a third front-of-pack shot, or an offer to "add a sticker later", which means domestic stock and your label problem.

3. Confirmation that a safety assessment exists. Article 10 obliges the responsible person to have a cosmetic product safety report before the product goes on the market, and Article 11 to keep the product information file at the address printed on the label. You are not asking for that file, and a supplier who refuses to hand it over is right to. Ask for written confirmation that the report exists and the file sits at that address. An evasive answer swaps in a factory GMP or free-sale certificate, neither of which says anything about the EU assessment.

4. Authorised distributor status, or a letter of authorisation. No EU rule requires one; brands and marketplaces do. A good answer is a letter naming your company, dated, with a territory and the brand contact who granted it. An evasive answer is "we are an official partner" with nothing attached, or a letter naming only the supplier and carrying no date.

5. Batch and shelf life, per line, before payment. Article 19(1)(c) drops the durability date for products lasting more than 30 months and requires the period-after-opening symbol instead, so a missing expiry date is not by itself a warning sign and the manufacturing date is the number to insist on. A good answer commits batch and date per line, in writing. An evasive answer is "fresh stock", which survives until the pallet is opened.

6. The invoice trail. The invoice must carry your registered company name and address, name the brand and the quantities, and show the price you actually pay. Article 70 of the Union Customs Code sets the customs value as the price actually paid or payable, so invoice, transfer and declaration have to tell one story. A Korean export sale carries no Korean VAT, so a 10 percent VAT line on one is money nobody refunds. An evasive answer offers to adjust the value, or invoices from an entity that is not the one you pay.

The two that carry weight

Items two and six. Everything else is a statement of intent: a notification reference is a claim you cannot test, a letter of authorisation a claim about a relationship you cannot see. The photograph and the invoice prove themselves, and they are what a third party comes back for later.

Article 6 makes checking that label your job before you make the product available, and if the responsible person's name and address are missing, those units were never lawfully placed on the EU market. Article 7 then obliges you to identify, for an authority, who supplied a batch and who you supplied it to, for three years after it reached you, and Article 51 of the Union Customs Code keeps the customs documents on your desk three years too.

Marketplaces run the same test: what unlocks a suspended account is an invoice from the brand or an authorised distributor, in the account holder's registered name, covering the quantity sold. One written for a value chosen to please customs fails months later. Both documents also separate EU stock from goods that are genuine but were never meant for this market, which is worth settling before the order rather than after.

The one that gets forged

The letter of authorisation. One page, a logo, and an issuer eight time zones away behind an address the supplier hands you. We see letters naming a company that dissolved years ago, scopes quietly widened to "worldwide", and the same letter recycled with a new buyer name pasted in. The certificate of authenticity is worthless but harmless; a forged letter is worse, because you believe it and stock against it.

The check is one email. Write to the brand through the address published on its own site, never the contact printed on the letter, and ask whether the supplier is authorised for your market. Brands answer this; they have every reason to. If the supplier objects to you asking, that is also an answer.

None of it makes you compliant. It tells you whose problem the compliance is, and whether you are the importer or a distributor decides most of your cost base.

The request, written out

Copy this, fill in the brackets, send it before the purchase order.

Subject: Documentation request before PO [ref]

Hello [name],

Thank you for the quote of [date]. I ask every supplier for the same six items before raising a purchase order. Please answer in this email rather than attaching a certificate pack.

For each line: the legal name and address of the EU responsible person, and the CPNP product reference.

For [SKU], [SKU] and [SKU]: a photograph of the back and the base of one actual unit from the lot you would ship. I am reading the responsible person's name and address, the country of origin and the language on the pack. Front-of-pack shots and press images do not work.

Written confirmation that a cosmetic product safety report exists for these products and that the product information file is held at the address on the label. I am not asking you to send the file.

Whether you are an authorised distributor for [brand] in [country]. If you hold a letter of authorisation, attach it with the name and email of the brand contact who issued it, so I can confirm it.

Per line: the batch number and the manufacturing date of the lot on offer. Where the pack carries a period-after-opening symbol instead of an expiry date, the manufacturing date is the one I need.

Confirmation that the invoice will be issued to [registered company name, address, VAT number], name the brand and the quantities, state the price I actually pay, and show no Korean VAT on an export sale.

Two notes to save time. A certificate of authenticity has nothing on it I can check, and a factory GMP or free-sale certificate does not answer question 3.

If any of these is a no, say so. Several of them I can work around. Finding out later, I cannot.

Best regards, [name]

Questions buyers ask

What if the supplier won't send a photo of the actual pack?

A second front-of-pack render instead of a photo of the back and base is a stall, not proof of anything. Push the purchase order date back until the photo arrives, because a label fixed after the goods clear customs is your problem, not the supplier's. If the same request goes unanswered for more than a few days, treat that silence as the answer: the pack does not yet carry an EU address.

Do I need a certificate of origin to import from Korea?

Only if you or the supplier wants the reduced or zero duty rate available under the EU-Korea Free Trade Agreement, in force since 2011. Without proof of preferential origin on the shipping documents, customs applies the standard duty rate that any non-EU cosmetics import pays, regardless of where the product was actually made. Origin proof is a paperwork question for your freight forwarder, not a reason on its own to reject a supplier.

Who is liable if a document turns out to be false after the order ships?

Regulatory liability for a non-compliant product sits with whoever places it on the EU market under Article 6 of Regulation (EC) No 1223/2009, not with whoever forged the letter. A false certificate does give you a contract claim against the supplier for misrepresentation, but that claim runs on your timeline and your legal costs, while a customs or market-surveillance authority acts on its own. Keeping the invoice and the email correspondence with the supplier is what turns a dispute into a documented one instead of a shouting match.

Sources

Articles and the Commission's CPNP access statement were read on EUR-Lex and the Commission's cosmetics pages on 1 September 2026. General information, not legal advice.

Stock these brands yourself?

Wholesale prices unlock once your trade account is approved. Verification takes one to two working days.

Apply for a trade account