EU and US Compliance for Glass Cosmetic Bottles
Imported from China

What EU Regulations Actually Apply

Glass cosmetic bottles imported from China and sold in the EU must comply with several regulatory frameworks — but none of them require a specific "import approval" or pre-market certification for the glass packaging itself. The requirements are about material safety and documentation:

• EU Cosmetics Regulation 1223/2009: Packaging must not alter the composition, quality, or safety of the cosmetic product. Standard glass is inert and meets this requirement by definition.
• EU Packaging Directive 94/62/EC: Heavy metal limits (lead, cadmium, mercury, hexavalent chromium) in packaging materials — maximum 100 ppm total.
• REACH Regulation 1907/2006: Substances of Very High Concern (SVHCs) in articles must be declared if present above 0.1% by weight. Certain glass colorants and decoration materials may contain SVHCs.
• EU Green Claims Directive (2026): Environmental claims on packaging must be substantiated — relevant if your packaging includes recycled content or sustainability claims.

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What Documents to Request from Your Factory

Document	When Required	Who Issues
Material composition certificate	All glass orders	Factory (internal)
REACH compliance statement	All orders for EU market	Factory (internal)
Heavy metal test report	Coloured glass, decorated, electroplated	SGS, BV, Intertek (third party)
RoHS certificate	Decorated or coated bottles	Third-party lab
MSDS for decoration materials	Any surface decoration	Decoration material supplier
ISO 9001 certificate	All orders (quality assurance)	Certification body

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Key Risk Areas — Where Problems Actually Arise

Metallic Decoration (Electroplating)

Full electroplating (gold, chrome, rose gold) on glass bottles sometimes uses processes involving cadmium, lead, or hexavalent chromium compounds. Always request a third-party heavy metal test report for electroplated bottles before importing. At Loci Glass, our electroplating processes comply with EU heavy metal limits — test reports are available on request.

Coloured Glass

Some glass colorants historically used lead or cadmium compounds. Modern cosmetic-grade coloured glass (amber, green, blue, black) uses transition metal oxides (iron, manganese, cobalt) that are compliant with EU limits. Request a glass composition certificate confirming the colorant chemistry.

UV or Metallic Coatings

Spray-applied coatings (UV coatings, metallic spray finishes) may contain solvents or compounds requiring REACH evaluation. Ask for the MSDS of the coating material used, and confirm it does not contain SVHCs above 0.1%.

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US Market — What the FDA Requires

The FDA does not regulate cosmetic packaging materials directly under cosmetic law. For standard cosmetic glass packaging, no FDA registration or certification is required. If your product has lip contact (lip gloss, lip serum) or is an oral hygiene product, food-contact grade glass standards (FDA 21 CFR) apply — confirm with your factory that the glass meets food-contact specifications.

The main US compliance burden is on the cosmetic product label (ingredient list, net weight in both metric and US customary units, manufacturer name and address) — not on the glass bottle itself.

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Practical Compliance Checklist for Your First Import

1. Request material composition certificate from factory before placing order
2. Request REACH compliance statement from factory
3. If ordering decorated or coloured glass: request third-party heavy metal test report
4. File your EU cosmetics notification (CPNP) for the finished product — this is separate from packaging compliance
5. Confirm customs HS code with your broker (7010.90 for glass packaging — duty 6.5% in EU)
6. Ensure wooden pallets carry ISPM 15 certification

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Frequently asked questions

Do glass cosmetic bottles from China need EU approval?

Glass cosmetic packaging does not require a pre-market approval or certification in the EU. However, it must comply with EU Cosmetics Regulation 1223/2009 requirements for packaging material safety — specifically, the packaging must not alter the composition or safety of the finished cosmetic product. For standard soda-lime glass, this is not an issue. Request a material composition certificate (soda-lime glass specification) from your factory.

What is REACH and does it apply to glass cosmetic bottles?

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals, EU Regulation 1907/2006) applies to chemical substances in articles, including packaging. For glass bottles, the relevant REACH concern is heavy metal content — specifically lead, cadmium, and arsenic, which may be present in glass colorants or decoration materials. Request a REACH compliance statement and RoHS certificate from your factory for any coloured or decorated bottles.

What heavy metal limits apply to glass cosmetic packaging in the EU?

EU Directive 94/62/EC on packaging and packaging waste sets heavy metal limits for the sum of lead, cadmium, mercury, and hexavalent chromium in packaging materials at a maximum of 100 ppm (100 mg/kg). Standard cosmetic-grade glass from Chinese factories meets this limit, but metallic decoration (electroplating) may introduce cadmium or lead-based compounds. Always request a heavy metal certificate for decorated bottles.

Does the US FDA regulate glass cosmetic packaging?

The US FDA does not specifically regulate cosmetic packaging materials as such — its authority is over cosmetic products. However, for food-contact glass (bottles that may also contain products ingested or applied to lips), FDA 21 CFR standards on glass composition apply. For standard cosmetic glass packaging (serum, perfume, lotion), a MSDS (Material Safety Data Sheet) confirming inert soda-lime glass composition is sufficient.

What documents should I request from a Chinese glass factory for compliance?

Request: (1) Material composition certificate confirming soda-lime glass specification, (2) REACH compliance statement, (3) RoHS certificate (for decorated bottles), (4) Heavy metal test report (SGS or Bureau Veritas) for any coloured, coated, or metallic-finish bottles, (5) ISO 9001 quality management certificate, (6) MSDS for any decoration materials applied to the glass surface.