DGCCRF Cosmetics Enforcement in France: What the Latest Inspection Trends Mean for Your Brand

The DGCCRF doesn’t announce its visits. That’s by design.

France’s consumer protection authority — the Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes — runs targeted inspection campaigns on cosmetic products every year, and they’ve become considerably more methodical about it. Across recent published survey cycles, non-conformity rates for cosmetic products have consistently exceeded 30% across certain product lines, with labeling deficiencies and unsubstantiated claims ranking among the top violations.

If you’re selling cosmetics into the French market — through a distributor, an e-commerce platform, or a French retail chain — this is the regulatory reality you’re operating in. The consequences of getting caught out aren’t minor: formal injunctions, mandatory product withdrawals, press releases published on the DGCCRF website, and in serious cases, referral to the public prosecutor under French criminal law.

What follows is a breakdown of what the DGCCRF actually reviews, what they keep finding, and what brands entering France — especially those from outside the EU — genuinely need to have in order before their products reach shelves.

How DGCCRF Enforcement of EU Cosmetics Regulation Works in Practice

The legal backbone here is EU Regulation (EC) No 1223/2009, which governs cosmetic products across all 27 EU member states. France implements it directly, but adds its own enforcement layer through the DGCCRF and — for specific vigilance and pharmacovigilance matters — the ANSM (Agence nationale de sécurité du médicament et des produits de santé).

The DGCCRF’s cosmetics investigations operate as annual campaigns targeting specific product segments. Recent cycles have covered sunscreens, hair colorants, nail products, products marketed as “natural” or “organic,” and self-tanning preparations. These aren’t random audits. Each campaign is preceded by market surveillance, analysis of complaint data, and typically a review of products being sold through major French e-commerce platforms. Inspectors go in knowing roughly what they expect to find.

What they primarily review is the Product Information File (PIF) and the product as labeled and presented to consumers. Under Regulation 1223/2009, the PIF must be maintained in France — or made accessible to French authorities — for the full commercial lifetime of a product plus 10 years after the last batch is placed on the market. That’s a long window, and many brands, particularly smaller importers, don’t have a structured PIF management system that can support it.

The Responsible Person (RP) requirement under Article 4 of Regulation 1223/2009 is where many non-EU brands stumble first. You must designate an EU-established Responsible Person before a single unit is sold on the French market. The RP is the legal touchpoint for both the DGCCRF and the ANSM: they hold the PIF, handle adverse event reporting under Article 23, and are accountable for CPNP notification. Without a French or EU-based RP on record, a brand is already non-compliant before the inspector has even looked at the label.

The Most Common Non-Conformities the DGCCRF Keeps Finding

Across the published DGCCRF enquête results from recent survey cycles, a handful of violations appear with remarkable consistency. These aren’t obscure technical failures — most are foundational compliance requirements that should have been addressed before market entry.

Labeling in French. This surprises many international brands. Under French law (Article L.111-1 of the Consumer Code and its implementing decrees), mandatory cosmetic label information must appear in French. This includes the product’s function, precautions for use, and all mandatory statements. INCI nomenclature is standard for the ingredient list and doesn’t require translation, but every other mandatory element — durability markers, warnings, usage instructions — must be readable in French. A product labeled solely in English, even with technically complete INCI notation, is non-compliant in France.

Unsubstantiated claims. DGCCRF investigators cross-reference product claims against the EU’s Common Criteria for cosmetic claims under Regulation (EU) No 655/2013, and they request substantiation files. Claims like “dermatologically tested,” “clinically proven,” or “100% natural” without supporting documentation are flagged as misleading or unverifiable. In the 2023 DGCCRF survey focused on “natural” and “organic” cosmetic claims, approximately 40% of the references inspected were found to be non-conforming — a figure that should concern any brand relying heavily on natural positioning.

CPNP notification errors. The Cosmetic Products Notification Portal is mandatory under Article 13 of Regulation 1223/2009, and notification must be completed before the product is placed on the EU market. The DGCCRF checks CPNP completion and will flag products where the notification is missing, incomplete (wrong formulation category, omitted nanomaterial declaration, outdated formulation), or where the notified product description no longer matches what’s on the shelf.

Prohibited and restricted ingredient violations. Annexes II and III of Regulation 1223/2009 list over 1,500 prohibited substances and approximately 300 restricted ingredients with specific conditions of use. The DGCCRF labs test product samples — typically 50 to 150 references per campaign depending on the category — and compare analytical results against these annexes. Hair products and nail preparations tend to generate the most analytical failures due to the chemical complexity of their formulations.

Preservative concentration discrepancies. Annex V of Regulation 1223/2009 specifies maximum authorised concentrations for preservatives. DGCCRF testing has flagged discrepancies between label declarations and actual concentrations across multiple survey cycles. This isn’t just a formulation error — it can constitute either a prohibited ingredient violation or a consumer information violation depending on whether the concentration is above or below the declared amount.

Why Online and Cross-Border Sellers Are Now Under Greater Scrutiny

The DGCCRF has meaningfully expanded its digital surveillance capability over the past three years. Inspectors now routinely monitor major French e-commerce platforms — Amazon.fr, Cdiscount, Veepee, and others — as part of their pre-investigation phase. This has two significant consequences for brands operating at a distance.

First, products sold by third-party sellers based outside France (or outside the EU entirely) are being caught in DGCCRF sweeps that would previously have been much harder to execute. A brand selling cosmetics on Amazon.fr from a UK entity post-Brexit, for example, is operating without valid Responsible Person designation if the RP hasn’t been transferred to an EU-established entity. The DGCCRF has specifically targeted this gap in recent campaigns, and it’s a systematic non-conformity — not an edge case.

Second, the claims made in product titles, bullet points, and enhanced content on e-commerce listings are treated as marketing claims subject to the same substantiation rules as label text. Brands that have clean physical labels but aggressive online copy — “repairs damaged hair in 7 days,” “visibly reduces fine lines in 14 days” — are finding that DGCCRF investigators review the full digital footprint, not just the packaged product.

The EU’s Digital Services Act (DSA) has reinforced this dynamic further. As platforms face stronger obligations around non-compliant product listings, they’re increasingly responsive to DGCCRF removal requests. A formal notification to an e-commerce platform can result in a product being delisted within 24 to 48 hours — faster than most brands can mobilise a legal response.

What to Have Ready Before the DGCCRF Reviews Your Products

Preparing for DGCCRF compliance isn’t mysterious. It’s thorough. And the preparation is almost entirely document-based.

A complete, current PIF that includes: (a) a cosmetic product safety report with a Part A safety profile and Part B safety assessment signed by a qualified cosmetic product safety assessor — someone meeting the qualifications set out in Article 10(2) of Regulation 1223/2009; (b) a product description; (c) a GMP compliance statement referencing EN ISO 22716:2007; (d) evidence supporting any claimed efficacy; and (e) substantiation data for every specific performance claim made on the label or in marketing materials.

An EU-based Responsible Person designation, confirmed in writing, with contact details that match those on the CPNP notification. The RP must be actively reachable — the DGCCRF expects responses to document requests within tight timeframes, and in the event of a serious safety issue, the ANSM may require a response within 24 hours.

A current CPNP notification that accurately reflects the formulation, category, function, and any nanomaterial or CMR substance declarations. If the formulation has been modified since original notification, an updated notification is required.

French-language labeling meeting the Article 19 requirements: INCI list, net quantity, durability indication (period-after-opening symbol or best-before date), batch reference, origin country for non-EU manufactured products, and full RP contact details in at minimum a French-language format.

Claim substantiation files for every performance or descriptive claim — test reports, consumer perception studies, scientific literature, or validated methodologies. “Natural” claims require particular care: French consumers and the DGCCRF alike scrutinise them closely, and the EU Commission guidance on cosmetic claims explicitly requires that “natural” positioning be objectively justifiable.

One point that’s worth stating plainly: if the DGCCRF contacts your Responsible Person requesting PIF access, the expectation is a prompt response — far shorter than the formal legal deadlines might suggest. Having a regulatory contact who can respond on short notice, and who maintains an organised, complete, and current PIF, is the practical difference between a manageable document review and a formal enforcement action that ends up on the DGCCRF’s public results page.

The French cosmetics market represents approximately €15.8 billion in annual consumption. Entry done correctly is an investment. Entry done carelessly is a liability.

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Written by Nour Abochama, Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex. Learn more about our team

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Related from our network

• ISO 17025-Accredited Cosmetic Analytical Testing — Qalitex Laboratories provides ingredient and contaminant testing to support EU cosmetic PIF safety profiles and DGCCRF-requested analytical substantiation.
• Cosmetic and NHP Testing for Canadian Brands Entering the EU — Androxa supports Canadian cosmetic brands with the laboratory data needed to meet EU Regulation 1223/2009 and French market entry requirements.