Licence · 粤卫消证字[2023]-07-第0002号·valid to 21 May 2027 (Disinfection-product hygiene licence)
EUROPEAN MARKET · GPSR · REACH · Heyuan, Guangdong
Selling into Europe starts with who is responsible.
Under Regulation (EU) 2023/988 no product may be placed on the EU market without an economic operator established in the Union responsible for it. That operator is your importer or your EU entity — not the factory. This page states which obligations are ours, which are yours, and which documents we hand over for the 20 SKUs we make. It does not claim a compliance status we do not hold.
- SKUs
- 20catalogue, quote-only
- Minimum order
- 2,000bottles per SKU
- Private label
- 25 dafter artwork approval
- GMP
- ISO 22716certificate + audit report
The boundary
What the factory carries, and what stays with you.
European buyers ask this in the first call and most suppliers answer it vaguely. Here it is as a table, because a table is what your compliance consultant will ask for anyway.
We supply
- — The formula, with INCI names, CAS numbers and function of each ingredient.
- — A 16-section SDS in the EU format, per formula family.
- — A COA per batch, and the retained sample behind it.
- — GMP / ISO 22716 certificate and the audit report it rests on.
- — Third-party laboratory reports, each with its number, published on this site.
- — A REACH/SVHC statement on our letterhead, and a declaration of what we do not use.
- — Pack weight and material data for your EPR filing.
- — Artwork printing, including your EU entity and address on the pack.
You, or your EU operator, carry
- — Naming an EU-established economic operator responsible under GPSR Art. 16.
- — The product classification: which regulation governs this SKU, on this formula, with these claims.
- — The label wording that follows from that classification.
- — REACH registration as the importer, and the SVHC communication down the chain.
- — Packaging EPR and, where applicable, WEEE registration in the member state of sale.
- — Import VAT, duty and the customs declaration.
- — Any product authorisation, where the SKU turns out to be biocidal.
This split is the ordinary one for a non-EU manufacturer. It is printed here so you can check it against your own adviser before the first call rather than after.
The file
Six documents, and who issues each.
| Document | Issued by | When you get it |
|---|---|---|
| Safety Data Sheet (SDS), 16-section, EU format | Us, per batch family | Before the first order, again if the formula changes |
| Certificate of Analysis (COA) | Us, per batch | With every shipment |
| Full ingredient declaration (INCI / IUPAC names, CAS where applicable) | Us | With the quotation, so you can classify the SKU before you commit |
| GMP / ISO 22716 certificate and the audit report behind it | Our certification body | With the quotation |
| Third-party laboratory reports (microbiology, heavy metals, stability) | Accredited laboratories, report numbers published on this site | With the quotation; verifiable by the report number |
| REACH statement on SVHC and the substances we do not use | Us, on our own letterhead | With the quotation |
Classification
Five regimes a pet care SKU can fall under.
The classification is made by the party placing the product on the market, from the full formula and the claims on the pack. What we can do is name the candidates, so you know which dossier to open first.
GPSR — Regulation (EU) 2023/988
filed by: An EU-established economic operator must be named as responsibleEvery consumer product placed on the EU market, since 13 December 2024, unless it is already covered by a harmonisation directive.
An EU-established economic operator must be named as responsible. Normally the importer or the EU brand owner.
Detergents Regulation — (EC) No 648/2004
filed by: The party placing it on the market: ingredient data sheet, allergen declaration, and biodegradability documentation for the surfactantsShampoos, foams and cleaners built on surfactants — most of the grooming line.
The party placing it on the market: ingredient data sheet, allergen declaration, and biodegradability documentation for the surfactants.
Biocidal Products Regulation — (EU) 528/2012
filed by: The applicant, through an EU-authorised product authorisationOnly where the product or its claims make it a biocidal product — a disinfectant claiming to kill or inhibit micro-organisms on surfaces or animals.
The applicant, through an EU-authorised product authorisation. The heaviest dossier of the four; it decides whether the SKU is sellable at all.
REACH — (EC) No 1907/2006
filed by: The EU importer registers; we supply composition and the SVHC statementAll of them. Registration duties sit with the EU importer; SVHC communication runs the length of the chain.
The EU importer registers; we supply composition and the SVHC statement.
Cosmetics Regulation — (EC) No 1223/2009
filed by: Not applicable to pet careHuman cosmetics only. It does NOT cover products for animals — a common mis-filing that surfaces at the customs broker.
Not applicable to pet care. Named here because it is the one buyers ask about.
Questions an EU importer asks us
The eight that come up before the first order, answered without rounding anything off.
- Do you have an EU responsible person under GPSR?
- No, not today. Under Regulation (EU) 2023/988 a product needs an economic operator established in the Union responsible for it, and that operator is normally the importer or the brand owner established in the EU. We supply the technical file that operator needs; we cannot be that operator ourselves, because we are not established in the Union. Any Chinese factory that tells you it is your GPSR responsible person is either misdescribing its role or naming a third party you should verify independently.
- What can you give me before I commit to an order?
- The full ingredient declaration with INCI and CAS names, the SDS in the 16-section EU format, the COA format, the GMP and ISO 22716 certificates with the audit report, the REACH/SVHC statement, and the third-party laboratory reports with their report numbers. Send the report number to the issuing laboratory and it will confirm the document — that is the point of publishing the numbers.
- Which regulation applies to a pet shampoo?
- Typically the Detergents Regulation (EC) No 648/2004 for the surfactant base, REACH for the substances, and GPSR for the general safety duty and the responsible operator. If the product or its claims make it biocidal — "kills bacteria", "disinfects" — BPR (EU) 528/2012 joins them, and it is a far heavier dossier. We will tell you which candidates apply to your formula; the classification itself is made by the party placing the product on the market.
- Can you print my EU label and my EU address on the pack?
- Yes. We print the artwork you supply, including your EU-established entity and its address, the batch number, the PAO or the "use by" marking, and the warnings your classification requires. We do not draft the label: the wording follows from the classification, which follows from the formula and the claims, and those are yours to own.
- Who handles EPR and packaging registration?
- The importer or the brand owner established in the EU. Packaging EPR, and WEEE where a device is involved, are registered by the entity placing the product on the market in that member state. We supply pack weight and material data in the format your EPR filing needs.
- What are the minimum order and the lead time for an EU shipment?
- 2,000 bottles per catalogue SKU, and 1,000 sets on the bundled sets. Private label runs 25 days after artwork approval. Catalogue SKUs ship from stock, and the lead time for the quantity you need is stated on the quotation. Terms are FOB or CIF against a named European port, quoted per order — this site publishes no unit price, because freight and volume move the number.
- Can you ship to a member state where I am not yet established?
- We can ship to the port or the warehouse you nominate. What we cannot do is make the goods lawful there before an EU operator takes responsibility for them — that is the importer's act, not the factory's.
- Will you quote in EUR?
- Yes, on request. The quotation is issued in USD by default and converted at the rate on the day it is issued; ask for EUR and the rate and the date are printed on the document.
Next step
Send one SKU, get the technical file back.
Name the product and the volume. The reply carries the ingredient declaration, the SDS, the certificate and the report numbers — enough for your consultant to say whether the SKU is worth pursuing before you spend anything on artwork.