HiSiaddi is an innovative foreign trade service provider driven by both technology commercialization and foreign trade operations. We have established a "1+2+3+4=1" service system and can supply original alkyl polyglucoside (APG) products from multiple well-known brand manufacturers. With over a decade of market experience and long-term factory technology transformation partnerships, HiSiaddi possesses extensive expertise addressing APG regulatory compliance issues. Below is a case resolving APG compliance risks.
Contact HiSiaddi customer service for more APG regulatory compliance consulting support.
Our partner is NATURE & SENS, a premium French organic beauty group specializing in organic skincare, fragrance essential oils and sensitive skin care products sold across Southern European markets including France, Italy and Spain. Its goods are supplied to high-end Parisian drugstores, organic beauty retailers and Michelin-starred hotel SPA supply chains. The group enforces zero-compromise standards: 100% plant-derived raw materials, valid organic certifications, zero irritation and full EU regulatory compliance, imposing strict requirements on APG REACH registration, ECOCERT/COSMOS organic certification, SVHC high-concern substance screening and RSPO sustainability certification. The group’s annual APG procurement volume totals 120 tons for all premium care and organic skincare formulas.
This marked the client’s first independent APG procurement from China. To cut costs, the client selected a low-quote manufacturer without conducting compliance due diligence. After the first 50-ton shipment arrived at Le Havre Port in France, EU customs detained the goods citing four major violations: incomplete REACH registration, invalid organic certifications, undeclared SVHC substances and non-compliant Safety Data Sheets (SDS). The shipment faced triple risks of return shipment, fines and delayed new product launches, prompting the client to entrust HiSiaddi’s compliance team with full incident resolution.
After coordinating with the client and French customs, HiSiaddi sorted out four fatal compliance loopholes, all mandatory entry thresholds for Southern Europe’s premium organic beauty market:
The supplying factory only completed pre-registration for APG substances without full formal registration. Furthermore, the registration entity was a domestic Chinese manufacturer lacking an EU-based legal representative, failing to meet REACH requirements for an EU Only Representative (OR). Customs ruled the registration invalid and prohibited goods entry.
The ECOCERT certification provided by the factory was a forged PSD template, while the COSMOS certification had expired six months prior. Additionally, the certification scope only covered industrial cleaning-grade APG and excluded cosmetic-grade material, entirely inconsistent with the client’s organic beauty application.
No full 251-item SVHC screening test reports were submitted to verify that phthalates, heavy metals, polycyclic aromatic hydrocarbons and other hazardous substances fell below EU limit values (e.g., DEHP ≤0.1%). Failure to complete mandatory SVHC notification for mixtures constituted a severe regulatory violation.
Supplied SDS documents were simplified Chinese versions instead of the 16-section full English format required by EU regulations. Critical supporting files including raw material traceability reports, batch consistency declarations, toxicological & ecotoxicological data and certificates of origin were missing, preventing completion of customs compliance verification.
Drawing on HiSiaddi’s EU REACH qualifications, cooperative channels for ECOCERT/COSMOS certification, SVHC testing resources and multilingual document drafting capabilities, our compliance team developed a four-dimensional remediation plan covering certificate supplementation, document restructuring, third-party testing endorsement and customs liaison, fully implemented within seven days:
We immediately terminated cooperation with the original non-compliant factory and switched to Yangzhou Chenhua (GreenAPG) and Shanghai Fakai (GreenAPG), two leading manufacturers holding complete formal REACH registration and EU Only Representative qualifications with EU legal registration entities, capable of providing REACH registration certificates, OR authorization documents and substance registration numbers to fully satisfy customs requirements.
Supplementary materials including full 103-section APG REACH registration dossiers, annual import volume declarations and supply chain compliance commitment letters were submitted to fully resolve invalid registration risks.
We coordinated Chenhua and Fakai to provide original English notarized copies of ECOCERT (valid through 2027) and COSMOS Organic certifications with explicit scope covering "cosmetic raw material – alkyl polyglucoside (APG) for organic cosmetic use".
We liaised with the China office of ECOCERT to issue an official authenticity verification letter for the certifications, alongside supplementary RSPO sustainable palm alcohol certification and HALAL certification to meet the client’s dual standards of organic formulation and sustainable sourcing.
We commissioned Eurofins, an EU-accredited third-party laboratory, to conduct full 251-item SVHC screening on replacement APG samples, issuing English test reports within five days confirming all substances were below EU limit values (no DEHP detected, heavy metals <10ppm).
We assisted the client in completing mandatory EU SVHC notification, submitting chemical safety assessment (CSA) reports, exposure scenario descriptions and risk control measures to fulfill statutory declaration obligations.
16-section full English SDS documents were drafted in strict alignment with EU CLP regulations, covering ingredient composition, physicochemical properties, toxicological data, transportation specifications and emergency response protocols.
A complete Technical Construction File (TCF) archive was organized including raw material traceability reports, batch test reports, production process specifications, certificates of origin, cruelty-free testing declarations and batch consistency commitment letters, all bilingual Chinese-English and officially stamped.
A joint EU Compliance Declaration (DoC) signed by HiSiaddi and new suppliers was provided, guaranteeing full compliance of products with REACH, ECOCERT and CLP regulations.
HiSiaddi’s EU compliance specialists communicated directly with customs at Le Havre Port in France, submitting fully remediated compliance document packages, certification credentials and test reports to explain corrective actions and regulatory basis item by item.
We assisted the client in supplementary submission of importer compliance declarations, end-use certification (organic cosmetic raw material) and customs tariff classification supporting documents to eliminate customs concerns and avoid secondary inspections.
· Full remediation completed in 7 days: All corrective measures and document submissions finalized within seven days of risk emergence, exceeding the client’s expectations.
· Smooth customs clearance: Customs verified all remediation materials, revoked detention orders and waived fines, enabling successful warehousing of the 50-ton APG shipment.
· Long-term valid credentials: Supplied REACH, ECOCERT and SVHC test reports remain valid for three years, eliminating repeat testing requirements for subsequent batches.
· Significant client loss mitigation: Avoided approximately €80,000 in regulatory fines, €300,000 in total shipment return losses and a 60-day delay to new product launches.
· Deepened long-term cooperation: The client terminated all partnerships with the original low-compliance supplier and designated HiSiaddi as exclusive APG procurement and compliance service provider, raising annual procurement volume to 150 tons and entrusting HiSiaddi with full compliance auditing for all raw material categories.
The root cause of this compliance crisis was the client’s unfamiliarity with EU high-end market regulatory rules combined with low-price suppliers providing forged or missing certifications, exposing typical blind spots for overseas mid-to-high-end clients sourcing Chinese chemical raw materials: prioritizing price over compliance and focusing solely on products rather than supporting regulatory documentation.
HiSiaddi’s core competitive advantage lies in comprehensive regulatory expertise, complete valid certification resources, actionable implementation capacity and rapid emergency response:
· Accurate identification of four mandatory EU compliance thresholds: REACH registration, ECOCERT organic certification, SVHC hazard substance control and compliant SDS documentation;
· Rapid remediation leveraging certified leading manufacturers to supplement valid credentials;
· Coordination with EU-accredited laboratories to deliver authoritative third-party testing endorsement;
· Compilation of full English regulatory document packages fully aligned with customs standards;
· Direct professional liaison with customs authorities to expedite shipment release.
For overseas premium beauty clients, China’s APG market features clear compliance tiering:
· Chenhua & Fakai: Top-tier fully compliant suppliers (REACH + ECOCERT + full SVHC testing)
· Wanqi: Basic compliant suppliers (REACH + partial organic certification)
· Generic small manufacturers: No valid certifications or forged compliance documentation
Selecting a foreign trade partner with full end-to-end compliance capabilities rather than merely comparing unit prices is the critical prerequisite for successful market entry into the EU premium segment.
Contact HiSiaddi customer service for more APG regulatory compliance consulting support.
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