Sell Cosmetics in Germany: Compliance Guide for the EU's Largest Market

• The BVL coordinates federal cosmetics oversight and Länder offices enforce market surveillance under Regulation (EC) 1223/2009 — Germany is the EU's largest cosmetics market at €16.94 billion in 2024.
• All consumer-facing label elements must be in German under §4 of the Kosmetik-Verordnung (KVO); INCI ingredient names are exempt.
• §3 KVO requires manufacturers and first EU importers to notify the competent Länder authority before placing products on the German market.

1. The EU framework applies — notify once, sell everywhere

Germany applies Regulation (EC) 1223/2009 directly — the harmonised rules that govern cosmetic products across the entire European Union. There is no parallel national regime: the safety, composition, and labelling rules are the same as in the rest of the EU.

In practice, selling in Germany within the EU framework means meeting four common obligations that are not specific to this country:

• A single CPNP notification covers the entire EU market, including Germany.
• A single EU-established Responsible Person is accountable for the product.
• A single product information file (PIF), which includes the cosmetic product safety report (CPSR).

This guide does not repeat that common framework — it focuses on what is specific to Germany. For the cross-cutting concepts, see also what the CosIng database is and how to use it.

2. The national competent authority

The federal reference authority is the Bundesamt für Verbraucherschutz und Lebensmittelsicherheit (BVL) — Federal Office of Consumer Protection and Food Safety. BVL acts as the national coordination point, handles serious undesirable effect (SUE) reporting coordination, and publishes the directory of Länder authorities for §3 KVO notifications.

Actual market surveillance is carried out by the food inspection offices or chemical and veterinary investigation offices of each of Germany's 16 federal states. Each Land has its own enforcement authority; BVL maintains the current list at: www.bvl.bund.de.

The BfR (Bundesinstitut für Risikobewertung — Federal Institute for Risk Assessment) contributes scientific risk assessment for cosmetic ingredient safety, providing technical support to BVL and the Länder authorities.

3. Labelling language requirements

German is mandatory for all consumer-facing label elements in Germany. The legal basis is §4 of the Kosmetik-Verordnung (KVO), the national regulation implementing Regulation 1223/2009 labelling requirements.

Elements that must appear in German include: nominal content, minimum durability date or period after opening (PAO), precautions for use, product function, and regulatory warnings. Other languages may appear alongside German, but German must not be smaller in font size than any other language.

INCI ingredient names are exempt from the language requirement: as internationally standardised nomenclature, they may appear in their original form without German translation.

Free samples must include the designation "Unverkäufliches Muster, nicht zum Verkauf bestimmt" (unsaleable sample, not intended for sale) or equivalent in German. In practice, Länder authorities also expect the product information file (PIF) to be available in a language they can readily understand — German is the preferred and expected language for market inspections.

4. National particularities

§3 KVO: pre-market notification to the Länder

Germany's most important national particularity is the §3 Kosmetik-Verordnung obligation: anyone who manufactures cosmetic products on German territory, or is the first EU importer of those products, must notify the competent Länder authority of the place of manufacture or import before first placing the product on the market. This notification is separate from CPNP and does not replace any obligation under Regulation 1223/2009 — it is an additional national requirement.

BVL publishes the list of Länder authorities that receive these notifications at: bvl.bund.de — §3 authority list.

LFGB: general consumer goods law

Articles 26–29 of the LFGB (Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch — Food, Consumer Goods and Feed Code) apply to cosmetics as consumer goods. They establish additional prohibitions and health protection provisions that operate alongside Regulation 1223/2009.

UWG litigation risk

Germany enforces the Gesetz gegen den unlauteren Wettbewerb (UWG — Unfair Competition Act) particularly actively in the cosmetics sector. Competitors in the German market can bring direct legal actions against companies that fail to comply with applicable regulations — without requiring intervention by a public authority. This competitor-initiated litigation risk is substantially higher than in most other EU member states and must be factored into any compliance strategy for Germany.

PIF language in practice

While there is no express statutory obligation to prepare the PIF in German, Länder authorities expect the file in a language they can readily understand. German is the preferred and expected language for market inspections. For guidance on PIF composition requirements, see the product information file guide and the CosIng database.

For other markets in the region, see our guides to France, Italy, Spain, and Poland.

5. Market context

Germany is the largest cosmetics market in the European Union. According to the Cosmetics Europe Annual Report 2024 (published June 2025), retail sales of cosmetic and personal care products reached €16.94 billion, placing Germany first in the EU and representing approximately 16% of total European sales (€104 billion in 2024 — the first time the European market has exceeded €100 billion).

This leadership reflects both the country's population size and its strong consumer culture around personal care products. For companies selling cosmetics in the EU, Germany is typically the priority market — but also the one with the greatest national regulatory complexity, particularly due to the fragmentation across 16 Länder and the UWG litigation risk.

6. Frequently asked questions

Which authority regulates cosmetics in Germany? The BVL (Bundesamt für Verbraucherschutz und Lebensmittelsicherheit — Federal Office of Consumer Protection and Food Safety) coordinates at federal level and publishes the list of competent Länder authorities. Actual market surveillance is carried out by the food inspection offices of Germany's 16 federal states.

What language must cosmetic labels be in for Germany? German is mandatory for all consumer-facing label elements under §4 of the Kosmetik-Verordnung (KVO). INCI ingredient names are exempt as international nomenclature.

Do I need a separate notification for Germany? No separate CPNP notification is needed — one notification covers the entire EU including Germany. However, §3 KVO requires anyone who manufactures cosmetics in Germany, or is the first EU importer, to notify the competent Länder authority of the place of manufacture or import before first placing the product on the market.

Are there national particularities beyond Regulation 1223/2009? Yes. Beyond §3 KVO, Articles 26–29 of the LFGB apply as a general consumer goods law. Germany also carries a significant UWG (Unfair Competition Act) litigation risk: competitors can bring legal actions directly against companies for regulatory non-compliance, without involving a public authority.