What is a CFS?
When exporting to third countries, companies are often asked to provide a Certificate of Free Sale (CFS) as part of their export dossier. A CFS is an attestation made by the EU Responsible Person that the product(s) complies with the EU Cosmetic Products Regulation (EC) No. 1223/2009 and may be freely sold across the EU. A CFS is also regarded as a 'Certificate of Manufacture' or a 'Health' or 'Safety Certificate' by certain non-EU countries.
Who can issue a CFS?
A CFS is issued on behalf of the EU Responsible Person.
The Responsible Person (RP) is a legal or natural person located in the EU responsible for ensuring that its products are safe and in full compliance with the Regulation. The RP is easily identifiable as its address is labelled on pack.
According to the EU Cosmetics Regulation, each cosmetic must be assessed for safety by a duly qualified safety assessor before it is made available to the public. The RP is also responsible to ensure that the product has been manufactured under Good Manufacturing Practices. This requirement applies even if the product has been manufactured by another entity such as a contract manufacturer. Information relating to each cosmetic product, including its formula, its method of manufacture and its safety assessment, must be readily available to the Competent Authorities of the Member State where the RP is located.
A CFS issued centrally in the country of the RP, regardless of manufacturing location, is therefore the accepted practice.
A CFS can be requested on behalf of the RP by its sub-contractors or consultants.
Which organisation in the UK can deliver a CFS?
A CFS, issued by the EU RP, is a valid document accepted by several countries. However, some authorities require the CFS to be issued by the national Competent Authority or a relevant organisation, which could be a trade association or a Chamber of Commerce.
In the UK, a CFS can be delivered by the Department of International Trade (DIT) on behalf of the RP - See https://www.gov.uk/import-controls. The DIT CFS declaration effectively confirm that the goods listed meet the UK/EU's high safety standards as they are being sold in the EU single market.
To apply for a CFS please go to: http://www.ilb.trade.gov.uk/
Is there any difference in the CFS issued by different Member States?
No, the CFS document may have variation in format, text, style and the issuing body, but the fundamental certification, that the product complies with the EU Cosmetic Products Regulation and may be freely sold throughout the EU, is the same.
Further information can be found on the Cosmetics Europe website at; https://www.cosmeticseurope.eu/publications-cosmetics-europe-association/guidelines.html?view=item&id=100&catid=46