How to Sell Supplements & Cosmetics in Germany Legally: BVL, CPNP & the Responsible Person

How to Sell Supplements & Cosmetics in Germany Legally: BVL, CPNP & the Responsible Person

How to Sell Supplements & Cosmetics in Germany Legally

Food supplement capsules and a bottle, representing EU supplement compliance
Food supplements. Photo: Rawpixel, CC0.

Germany and France are Europe's two largest markets for food supplements and beauty products, which makes Germany a natural first target for ambitious Indian brands. But entering it legally is specific: food supplements must be notified to the BVL, cosmetics must be notified in the EU's CPNP portal, and both need an accountable Responsible Person established in the EU.

Key takeaways. Food supplements sold in Germany must be notified to the Federal Office of Consumer Protection and Food Safety (BVL). Cosmetics must be notified in the EU-wide Cosmetic Products Notification Portal (CPNP) and require an EU-based Responsible Person who takes legal accountability for safety. Notification is not approval — the obligation to be compliant stays with you. And an importer bringing goods from India into the EU carries real legal duties, which is why most serious brands appoint an EU partner to hold these roles.

 

Step 1 — Know which rulebook applies

The first mistake Indian brands make is treating a product by its marketing category ("wellness", "ayurvedic beauty") rather than its legal one. In the EU, the legal category decides everything:

  • Food supplement — a concentrated source of nutrients or botanicals, taken in measured doses. Governed by EU and German food law.
  • Cosmetic product — applied to the skin, hair, teeth, etc. Governed by the EU Cosmetic Products Regulation.

Get this classification wrong and every downstream step — notification, labelling, claims — is wrong too.

Step 2 — Food supplements: notify the BVL

To place a food supplement on the German market, you must notify the Federal Office of Consumer Protection and Food Safety (BVL) by submitting a product sample/label. The BVL forwards your notification to the competent state authorities, who monitor compliance.

One point is widely misunderstood: BVL notification is not an approval. The BVL does not confirm that your product is lawful or marketable. The responsibility to ensure the product complies with food law — ingredients, doses, labelling, claims — stays entirely with the business placing it on the market.

Step 3 — Cosmetics: notify in the CPNP and appoint a Responsible Person

For cosmetics, the EU runs a single notification system: the Cosmetic Products Notification Portal (CPNP). Once a product is notified in the CPNP, no further national notification is needed within the EU. But before you can notify, two things must be in place:

  • A Responsible Person (RP) established in the EU. For an imported product this is usually the importer or an appointed representative. The RP must be based in the EU and is legally accountable for the product's safety and compliance.
  • A Product Information File and safety assessment. Every cosmetic must have a documented safety assessment (CPSR) and a compliant Product Information File before it goes on sale.

Step 4 — Understand what the "Responsible Person" really carries

The Responsible Person is not a formality. This is the legal entity that authorities hold accountable if a product is unsafe, mislabelled or non-compliant — including obligations around documentation, adverse-event reporting and cooperating with regulators. Because it carries genuine liability, the RP should be an EU-established party that actually understands the product, not a name of convenience.

Step 5 — Get the goods there: import, customs and VAT

Legal notification is only half the job. Physically importing from India into Germany means EU customs clearance, correct classification and duties, and VAT registration (typically with OSS for cross-border EU sales). A product that is compliant on paper but stuck at customs still isn't selling.

Want Germany handled end to end?

Meridian acts as your European partner — classification, BVL/CPNP notification, EU Responsible Person, customs and fulfillment — under one relationship and one invoice.

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Frequently asked questions

Do I need to register food supplements in Germany?

Yes. Food supplements must be notified to the BVL (Federal Office of Consumer Protection and Food Safety) before being placed on the German market. Note that this notification is not an approval — compliance responsibility remains with the business selling the product.

What is the CPNP and do I need it for cosmetics?

The CPNP is the EU's Cosmetic Products Notification Portal. Every cosmetic product must be notified there before it is placed on the EU market. Once notified in the CPNP, no additional national notification is required within the EU.

What is an EU Responsible Person and do I need one?

The Responsible Person is an entity established in the EU that is legally accountable for a cosmetic product's safety and compliance. You cannot legally place a cosmetic on the EU market without one. For imported products it is typically the importer or an appointed EU representative.

Can an Indian company sell directly into Germany without an EU entity?

Compliance roles such as the cosmetics Responsible Person must sit with an EU-established party, and importing carries EU legal duties. In practice, most Indian brands appoint an EU partner to hold the importer, Responsible Person and VAT roles so the product can be sold legally and accountably.

Is Germany a good first market for Indian wellness brands?

Germany is Europe's largest supplement and beauty market, which makes it attractive — but it is also strict and well-policed. It rewards brands that enter fully compliant and punishes those that cut corners, so it should be entered with the paperwork right from day one.

Sources: BVL — notification of food supplements for sale in Germany; European Commission — Cosmetic Product Notification Portal (CPNP); EU Cosmetic Products Regulation (EC) No 1223/2009 (Responsible Person and safety assessment). This article is general information, not legal or regulatory advice; confirm current requirements for your specific products before selling.

Meridian Advisory is the trading name of Herbs Fusion SRL, a company established in the European Union (Romania).

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Herbs Fusion SRL, trading as Meridian Advisory · established in the European Union (Romania)