To start a cosmetics brand in Switzerland you need no licence, no product registration and no prior notification: no Swiss authority approves a cosmetic before it is sold, and perfume follows exactly the same rules. The trade-off is responsibility. Once your name or trade mark is on the pack, Swiss law treats you as the manufacturer, even if a contract laboratory formulates, fills and packs everything. Before your first sale you must hold a product information file with a safety assessment signed by a qualified person, a compliant label and evidence for every claim. This guide takes those duties in turn, then explains what changes when you sell into the European Union.
Contents
- No licence, but a complete regime
- Your brand makes you the manufacturer
- Product information file and safety assessment
- Ingredients: the EU annexes apply in Switzerland
- The label, item by item
- What you may claim
- Perfume: a cosmetic with alcohol
- Swiss made: the 60 per cent rule
- Selling into the EU
- Company, trade mark, customs and VAT
- Costly mistakes
- FAQ
No licence, but a complete regime
No cosmetic needs an authorisation to be sold in Switzerland, and no public register lists the products on the market. The Foodstuffs Act would allow the Federal Council to require conformity procedures or notification for certain utility articles (Art. 15(5)(a)), but it has not done so for cosmetics, and the duty to notify a business activity in the Food and Utility Articles Ordinance only covers foodstuffs (Art. 20). Cantonal authorities confirm this in practice: in Geneva, the consumer affairs service (SCAV) states on its page on importing utility articles, updated on 31 August 2026, that it issues neither import authorisations nor certificates of conformity.
Enforcement happens afterwards. Cantonal chemists sample products, request the file and can order a recall. And because no authority approves a cosmetic, a label or website claiming that a product has been “approved by the authorities” is itself unlawful under the claims criteria of the Cosmetics Ordinance (OCos, Annex 6, point 1.1).
Your brand makes you the manufacturer
Under the OCos, the manufacturer is any natural or legal person who manufactures a cosmetic product, or has it designed or manufactured, and markets it under their own name or trade mark (Art. 2(1)(c)). A private label brand whose formula and filling are entirely outsourced is therefore the manufacturer in law, and must ensure that the products it places on the market comply with food and utility articles legislation (Art. 3(1)).
Three further rules complete the picture:
- Distributors who rebrand take on the manufacturer’s duties when they place a product on the market under their own name or modify it in a way that may affect compliance (Art. 3(3) OCos).
- A person responsible in Switzerland: every establishment in the utility articles sector must appoint a responsible person with a business address in Switzerland; failing that, the management is responsible (Art. 73 of the Food and Utility Articles Ordinance). A foreign brand may instead appoint, by written mandate, an agent with a Swiss address who takes on the manufacturer’s obligations (Art. 3(2) OCos).
- Self-supervision: “Any person who manufactures, handles, stores, transports, places on the market, imports, exports or carries in transit foodstuffs or utility articles must ensure that the statutory requirements are complied with” (Art. 26(1) Foodstuffs Act). For cosmetics this covers safety checks, good manufacturing practice, traceability, withdrawal and recall, and documentation, scaled to the risk and the volume produced.
Product information file and safety assessment
The product information file (PIF) is the core of compliance. It must exist before the product is first placed on the market and must contain a safety report with an assessment of the product’s safety (Art. 57(1) Food and Utility Articles Ordinance). The Federal Food Safety and Veterinary Office (FSVO) repeats on its cosmetics page, updated on 29 May 2026, that a PIF with a safety report is always mandatory.
Article 5 OCos lists its content: a description of the product, the safety report under Annex 5, the manufacturing method with a declaration of compliance with good manufacturing practice, proof of the claimed effect where the nature or effect of the product justifies it, and data on any animal testing. The file may be written in a Swiss official language or in English and must be kept for ten years after the last batch was placed on the market (Art. 5(2)). Information must be available to cantonal authorities for three years (Art. 13). If a compliant file already exists abroad for the same product, it can be used in Switzerland (Art. 5(3)), which means a brand selling in both markets needs one file, not two.
The safety assessment cannot be signed by the founder unless they hold the right qualification: it must be carried out by a person with a university degree in pharmacy, toxicology, medicine or a similar discipline, or a recognised equivalent (Art. 4(5) OCos), and it must be updated as new information emerges after launch. Ask your contract manufacturer for evidence of compliance with SN EN ISO 22716, the good manufacturing practice standard referenced in Annex 7 OCos (Art. 12(3)).
Your beauty brand in Switzerland
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Ingredients: the EU annexes apply in Switzerland
Switzerland keeps no separate list of banned or restricted cosmetic ingredients. Article 54 of the Food and Utility Articles Ordinance bans the substances in Annex II of Regulation (EC) No 1223/2009 and admits those in Annexes III to VI (restricted substances, colourants, preservatives, UV filters) only on the conditions set by that Regulation, in the version in force in the EU. Any change to the EU annexes therefore applies in Switzerland without transposition.
Swiss law adds its own rules. Substances classified as carcinogenic, mutagenic or toxic for reproduction in categories 1A, 1B or 2 are banned, with listed exceptions (Art. 6(2) OCos). Since 1 January 2026, leave-on products that may be exposed to sunlight must contain less than 1 mg/kg of eight listed furocoumarins, but perfumes, eaux de toilette and eaux de Cologne are exempt (Art. 6(1) OCos). Anything meant to be swallowed, inhaled, injected or implanted is never a cosmetic; a “beauty from within” capsule falls under food supplement law, covered in our guide on starting a supplement company in Switzerland.
The label, item by item
Label information must be clearly visible, legible, indelible and written in at least one Swiss official language (Art. 47(2) Food and Utility Articles Ordinance).
| Item | What it must show | Basis |
|---|---|---|
| Ingredients list | Headed “Ingredients”, in descending order of weight, using the EU glossary (INCI) names, with “[nano]” where relevant | Art. 8 OCos |
| Fragrance | “Parfum” or “aroma”, plus any substances whose declaration is required (allergens) | Art. 8(1)(d) OCos |
| Responsible party | Name and address of the manufacturer, importer, distributor or EU responsible person | Art. 9(1)(b) OCos |
| Durability | Date of minimum durability, or period after opening where durability exceeds 30 months | Art. 9(1)(c) and (d) OCos |
| Batch | Batch number or reference | Art. 9(1)(f) OCos |
| Precautions | Precautions for use and required warnings, set apart from the rest of the label | Art. 9(1)(g) and (2) OCos |
Source: Cosmetics Ordinance (SR 817.023.31, as in force on 1 January 2026) and Food and Utility Articles Ordinance (SR 817.02).
One rule helps brands selling on both sides of the border: the Swiss label may show the address of the EU responsible person under Regulation 1223/2009 (Art. 9(1)(b) OCos). A single, well-designed pack can serve both markets.
What you may claim
“All information relating to foodstuffs, consumer articles and cosmetics must correspond to the facts” (Art. 18(1) Foodstuffs Act), and presentation, labelling and advertising must not mislead consumers, in particular about composition, production method, country of production, origin of raw materials or particular effects (Art. 18(2) and (3)). The OCos adds that no claim may attribute characteristics or functions the product does not have (Art. 10(1)) and sets detailed criteria in Annex 6:
- Evidence: explicit or implicit claims must be supported by adequate and verifiable evidence (point 3.1); highlighting an ingredient requires proof of an effective concentration in the finished product (point 3.6).
- No denigration: claims may not denigrate competitors or ingredients used legally (point 5.1), which puts prominent “free from” claims at risk.
- No inflated basics: implying a special benefit when the product merely meets legal minimum requirements is not allowed (point 1.3).
- No therapeutic claims: curative, soothing or preventive properties are prohibited for utility articles (Art. 47(3) Food and Utility Articles Ordinance). A “healing” cream leaves cosmetics law; see our guide on starting a medical device company for what begins there.
A cosmetic whose final formulation or ingredients were tested on animals to meet legal requirements or assess its cosmetic effect may not be placed on the market, save for an FSVO derogation (Art. 59 Food and Utility Articles Ordinance). A “not tested on animals” claim is only lawful where neither you nor your suppliers carried out or commissioned such tests on the product, its prototype or its ingredients (Art. 10(3) OCos).
Perfume: a cosmetic with alcohol
Perfume has no separate regime. The Food and Utility Articles Ordinance defines cosmetics as preparations applied to the external parts of the body with the purpose of cleaning, perfuming, changing their appearance, protecting them or correcting body odours (Art. 53(1)). An eau de parfum therefore follows the same rules as a face cream: manufacturer status, PIF, safety assessment, labelling, allergens declared next to “parfum”.
The difference is alcohol. Products containing alcohol that are unfit for consumption are not subject to alcohol tax (Art. 31(1) Alcohol Act). But anyone who wants to use undenatured, untaxed alcohol to make products unfit for consumption must apply for a use authorisation from the Federal Office for Customs and Border Security (FOCBS) (Art. 32(1) Alcohol Act). A brand buying a pre-diluted concentrate or already denatured alcohol is outside that rule; a brand opening its own composition studio is inside it from the first litre.
Scented candles and home fragrances are not cosmetics, since they are not applied to the body; candles are a separate category of utility article (Art. 5(f) Foodstuffs Act), and room fragrances follow other rules than the OCos.
Swiss made: the 60 per cent rule
“The origin of other products, in particular industrial products, corresponds to the place where at least 60 per cent of the manufacturing costs are incurred” (Art. 48c(1) Trade Mark Protection Act). Research and development, manufacturing and assembly, and legally required quality assurance count (Art. 48c(2)); natural products that cannot be produced in Switzerland because of natural conditions, packaging, transport and marketing costs do not (Art. 48c(3)). In addition, “an essential manufacturing step must have been carried out at this place” (Art. 48c(4)).
For a cosmetics brand this cuts both ways. A formula developed in Switzerland counts, and an essential oil that cannot be grown in Switzerland is left out of the calculation; but the bottle, the box and the launch campaign never count. A “Swiss” brand whose formula and production are entirely foreign cannot use the cross, and presenting it as Swiss also misleads on the country of production under Art. 18 Foodstuffs Act. Our guide on starting a manufacturing company in Switzerland explains the Swissness logic for manufactured goods.
Selling into the EU
EU law adds a condition Switzerland does not impose: “Only cosmetic products for which a legal or natural person is designated within the Community as ‘responsible person’ shall be placed on the market” (Art. 4(1) Regulation (EC) No 1223/2009). A Swiss company is not established in the EU. To sell in Germany, France or Italy, the brand either works through an EU importer, which becomes the responsible person for the products it places on the market (Art. 4(5)), or appoints by written mandate an EU-established person who accepts in writing.
That responsible person notifies each product to the Commission through the Cosmetic Products Notification Portal (CPNP) before it is placed on the market, with the product category and name, the address where the PIF is available, the country of origin for imports, the Member State of first sale, contact details, nanomaterials, CMR substances and frame formulation (Art. 13(1)). Switzerland has no equivalent notification.
A typical case: a founder based in the United Arab Emirates sets up a GmbH in Zug for a skincare line produced by an ISO 22716-certified contract manufacturer in Ticino and sold online to Swiss and German customers. She is the manufacturer under the OCos, holds the PIF before the first Swiss sale and has the safety assessment signed by a toxicologist. For Germany, she appoints a responsible person in Munich who notifies each product to the CPNP and keeps the same file available; that person’s address appears on the label, which Swiss law also accepts. No authority issued a licence, yet every step is documented.
Company, trade mark, customs and VAT
A GmbH with share capital of CHF 20,000 fully paid in suits most brands at launch; an AG with CHF 100,000 of share capital, of which at least CHF 50,000 is paid in, fits once an investor or a major distributor comes in. The steps are set out in our guide to the incorporation of a company in Switzerland.
Register the trade mark before printing packaging. At the Swiss Federal Institute of Intellectual Property (IPI), the filing fee is CHF 450 for ten years and up to three classes, with a CHF 100 discount for electronic filing and CHF 100 for each additional class; cosmetics and perfumery fall in class 3. A Swiss trade mark does not protect you in the EU, where a separate EU or international filing is needed.
On imports, Switzerland abolished all customs duties on industrial products, chapters 25 to 97 of the Harmonised System, on 1 January 2024. Cosmetics and perfumes, in chapter 33, enter duty-free; import VAT at the standard rate of 8.1 per cent still applies.
Costly mistakes
- Assuming the laboratory carries the liability: under your brand, the manufacturer in law is you.
- Selling before the PIF exists: the file and safety report must be in place before first placing on the market.
- Having the safety assessment signed by someone without the required degree (Art. 4(5) OCos).
- Claiming approval or certification by an authority: no authority approves cosmetics.
- Promising a therapeutic effect, even through imagery or a product name.
- Using the Swiss cross below 60 per cent, or counting the bottle and the advertising in the calculation.
- Launching in the EU without a responsible person and a CPNP notification.
- Composing perfume with pure ethanol without a FOCBS use authorisation.
FAQ: starting a cosmetics brand in Switzerland
Do you need a licence to sell cosmetics in Switzerland?
No. No authorisation, registration or prior notification is required before a cosmetic is placed on the Swiss market, and cantonal services such as the SCAV in Geneva issue neither import authorisations nor certificates of conformity. The manufacturer must, however, hold a product information file with a safety report before the first sale (Art. 57 Food and Utility Articles Ordinance) and carry out self-supervision (Art. 26 Foodstuffs Act).
Who is legally responsible for a private label cosmetic?
The brand. Article 2(1)(c) of the Cosmetics Ordinance defines the manufacturer as the person who manufactures a cosmetic, or has it designed or manufactured, and markets it under their own name or trade mark. The contract laboratory provides manufacturing and good manufacturing practice (ISO 22716); the brand ensures the product complies and keeps the file for ten years.
Who can sign a cosmetic safety assessment in Switzerland?
A person holding a university degree in pharmacy, toxicology, medicine or a similar discipline, or a recognised equivalent qualification (Art. 4(5) Cosmetics Ordinance). The assessment follows Annex 5 of the Ordinance, takes account of intended use and exposure to each ingredient, and must be updated when relevant new information appears after launch.
Is perfume a cosmetic under Swiss law?
Yes. Article 53(1) of the Food and Utility Articles Ordinance includes preparations intended to perfume the external parts of the body. Perfume therefore follows the Cosmetics Ordinance: PIF, safety assessment, labelling and allergen declaration. In addition, composing with undenatured, untaxed alcohol requires a use authorisation from the FOCBS (Art. 32(1) Alcohol Act).
Can a cosmetic be labelled Swiss made if made partly abroad?
Yes, if at least 60 per cent of its manufacturing costs are incurred in Switzerland and an essential manufacturing step takes place there (Art. 48c Trade Mark Protection Act). Research and development count; packaging, transport, marketing and natural raw materials that cannot be produced in Switzerland are excluded from the calculation.
Do you need a CPNP notification to sell in Switzerland?
No. The CPNP is an EU tool: the EU responsible person uses it to notify products before they are placed on the EU market (Art. 13 Regulation 1223/2009). Switzerland has no equivalent notification. A Swiss brand that also sells in the EU must, however, appoint an EU-established responsible person who handles that notification.
Sources
- FDHA Ordinance on Cosmetics (OCos), SR 817.023.31 (official versions in French, German and Italian)
- Food and Utility Articles Ordinance, SR 817.02
- Foodstuffs Act, SR 817.0
- FSVO, cosmetic products (29 May 2026)
- SCAV Geneva, importing utility articles (31 August 2026)
- Regulation (EC) No 1223/2009 on cosmetic products
- Trade Mark Protection Act, SR 232.11, Art. 48c
- Alcohol Act, SR 680, Art. 31 and 32
- FOCBS, abolition of industrial tariffs on 1 January 2024
- IPI, trade mark costs
Conclusion
Starting a cosmetics brand in Switzerland involves no licence, which is exactly why everything rests on the brand: a complete file before the first sale, a safety assessment signed by the right person, an accurate label, claims you can prove, a Swiss cross you have earned, and for the EU a responsible person and a CPNP notification. Brands that organise themselves this way from day one pass cantonal checks smoothly and enter the EU without rebuilding their file. My Swiss Company, a Swiss Corporate Services Provider with offices in Geneva and Lucerne and a presence in Zug, incorporates and administers brand companies for founders from more than 20 countries, from incorporation to inventory accounting and VAT.
