What a limited inspection covers, and what it does not
Whether a cosmetic is safe depends on its formula, its raw materials and how it was made, and those are proved by the safety assessment, lab tests and the manufacturer's records. An inspector at the factory cannot see any of that by looking at a jar. What the inspector can check is that the goods in the cartons are the goods described in your documents, filled, labelled and sealed as agreed, and that the samples sent to the lab come from that lot. We call this a limited inspection.
| We check | We do not do |
|---|---|
| Quantity by product, shade and size against the purchase order | Formula, ingredient or purity analysis |
| Fill level and net content by weight or volume on a sample | Microbiology, stability or preservative efficacy tests |
| Closures, pumps, droppers and roll-ons for leaks | Safety assessment or a cosmetic product safety report |
| Labels against approved artwork, batch code, expiry or period after opening | Regulatory sign-off, notification or registration |
| Tamper seals, shrink sleeves, cartons and shipping marks | A GMP certification audit |
| Random samples drawn, sealed and sent to an accredited lab | Lab testing on site |
Lab tests go to an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination. We have no partner labs and take no lab commissions.
What every cosmetics inspection checks
- Net content. Units are weighed on a calibrated scale, net of the empty pack, and compared with the declared quantity. Oils and attars are also checked for fill height in clear glass.
- Leaks and closures. Bottles are inverted and squeezed where safe; caps, droppers, roll-on balls and pump actuators are checked for fit, drips and cracked necks.
- Labels. Product name, ingredient list, nominal content, batch code, date of minimum durability or period after opening, warnings, the responsible person's name and address and the country of origin are read against your approved artwork for each market.
- Batch and date coding. Codes are legible, match the packing list and the certificate of analysis, and are the same on the unit, the carton and the shipping carton.
- Seals and packaging. Induction seals, shrink bands and carton tamper tapes in place; no dented tins, crushed cartons or stained labels.
- Appearance against the retained sample. Colour, texture and smell are compared with the approved sample as a screen; any doubt goes to the lab.
- Samples. Units are drawn at random from packed cartons, sealed with numbered tamper tape, photographed and sent under chain of custody, with a counter-sample kept if you ask.
Sample sizes follow ISO 2859-1; see the AQL guide. The report ends with one verdict: Cleared to load, Hold or Not cleared.
How the checklist changes by product
| Product | Main risks | What the inspector adds |
|---|---|---|
| Henna and mehndi powder | Sand and other plant matter; PPD ("black henna") adulteration; skin-use claims on hair-only henna | Pack weight and seal, feel and colour against the sample, label claims for each market, samples for lawsone, ash and PPD |
| Attars and perfume oils | Leaking roll-ons, broken glass vials, short fill | Fill height, inverted leak check, vial and cap fit, label and batch code |
| Essential oils | Wrong or diluted oil, missing hazard labels, drums that weep | Drum and bottle seals, net weight, labels and child-resistant closures as specified, samples for GC analysis |
| Handmade soaps | Weight loss after curing, sweating, cracks, rancid spots | Bar weight against the declared weight, surface condition, wrapper seal |
| Herbal and Ayurvedic cosmetics | Leaks, missing dates, drug-style claims on the label | Fill and leak checks, label claims against your approved wording, tamper seals |
Market rules that shape the checklist
| Market | Rule | What it means for the goods |
|---|---|---|
| EU | Regulation (EC) 1223/2009, Article 4 (responsible person) | A cosmetic may only be placed on the market if a legal or natural person in the EU is designated as responsible person. An Indian maker usually relies on its buyer or an appointed agent |
| EU | Articles 10, 11 and 13 | Safety assessment and safety report before sale; a product information file kept for ten years after the last batch; notification through the Commission's portal (CPNP) before sale |
| EU | Article 19 (labelling) | Responsible person's name and address, country of origin for imported products, nominal content, date of minimum durability or period after opening, precautions, batch number, function and ingredient list |
| EU | Regulation (EU) 2023/1545 (fragrance allergens) | More fragrance allergens must be named on the label above 0.001% in leave-on and 0.01% in rinse-off products. Products that do not comply could be placed on the market until 31 July 2026 and made available until 31 July 2028 |
| US | Modernization of Cosmetics Regulation Act of 2022 (MoCRA) | Facility registration, renewed every two years; product listing by the responsible person; serious adverse event reports within 15 business days; records of safety substantiation. Some small businesses are exempt from registration and listing |
| US | FDA colour additive rules, e.g. 21 CFR 73.2190 for henna | Colour additives may be used only as approved: henna is approved for colouring hair only |
The inspector checks labels and documents against these requirements as set out in your artwork and specification. Whether a formula complies is a question for your safety assessor and the lab.
Where these products are made in India
Two products in this industry have a registered Geographical Indication. We name a town only where an official record supports it.
| Place | Official record | Products |
|---|---|---|
| Kannauj, Uttar Pradesh | "Kannauj Perfume" GI, application 157, certificate dated 31 Mar 2014, valid to 8 Feb 2029 | Attars and perfume oils |
| Sojat, Pali district, Rajasthan | "Sojat Mehndi" GI, application 628, certificate dated 14 Sep 2021, valid to 12 Nov 2028 | Henna leaf and powder |
We have not found an official export total for cosmetics, toiletries and essential oils, so we do not quote one. Essential oils, soaps and herbal cosmetics are made in many states; we inspect wherever your supplier is. Sojat is about 100 km from Jodhpur, where Clear To Load is based.
Booking a cosmetics inspection
An inspection costs US$249 per man-day, with travel set by travel band, and lab testing coordination costs US$99 per order on top of the lab's own fees. Send the approved artwork for each market, the specification with declared quantities and tolerances, the certificate of analysis you hold and a list of the lab tests you want. The inspector checks the goods against those documents and draws the samples the lab needs.
Clear To Load is not a regulatory consultant and does not act as an EU responsible person or a US registrant. Book an inspection.
Sources
- Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
- Commission Regulation (EU) 2023/1545, fragrance allergen labelling (EUR-Lex)
- FDA: Modernization of Cosmetics Regulation Act of 2022 (MoCRA)
- 21 CFR 73.2190, henna
- IP India GI Registry: Kannauj Perfume, application 157
- IP India GI Registry: Sojat Mehndi, application 628