How-to
Buying French skincare wholesale for a US business
Short answer
Keep claims cosmetic and leave sunscreens out: in the US they are drugs. Commercial terms are available in your trade account once your business is verified.1 Endless Pure offers an attractive margin up to 50%.
Key facts
- Under MoCRA, the responsible person is the manufacturer, packer or distributor whose name appears on the cosmetic's label.2
- The responsible person lists each marketed cosmetic with FDA, including ingredients, and updates listings annually; manufacturing and processing facilities register and renew every two years.3
- Serious adverse events must be reported to FDA no later than 15 business days after the responsible person receives the report.4
- In the United States, sunscreens are regulated as drugs and must meet nonprescription drug standards.5
- Endless Pure offers an attractive margin up to 50%. Prices are available after registration.
Can a US spa or store buy French skincare direct from the brand?
Yes, if the brand publishes US terms and you are prepared to import. The difference is the border. Duties and taxes are paid on arrival, and you are the importer.
It suits med-spas and dermatology practices that want a certified home-care line, day spas building a retail wall, and independent stores curating European clean beauty.
What does an order cost to land, in dollars?
Goods plus duty plus the broker's fee, converted at your bank's rate.
| Product | Units |
|---|---|
| Bio-Retinol Serum | 6 |
| Bio-Retinol Elixir Moisturiser | 6 |
| Double Peptide Serum | 4 |
| Peptide Smoothing Eye Cream | 4 |
| PURE CALM Night Recovery Cream | 4 |
| Hyaluronic Double Hydration Gel | 4 |
| Eye Renewal Patches | 3 |
| Total | 31 |
Multiply each trade price in your account by that factor before you set a shelf price (US prices exclude sales tax), and check that the margin left still covers shipping, card fees and promotions.
Set US prices from landed cost, not from the euro RRP. For margin and price-ending logic, see the retail price and margin guide.
Who carries the MoCRA duties when you import?
The company named on the label. MoCRA defines the responsible person as the manufacturer, packer or distributor whose name appears on the cosmetic's label.2 That party lists each marketed product with FDA, including its ingredients, and updates the listing annually.3 It keeps records supporting the product's safety substantiation and reports serious adverse events.6
Facility registration is a separate duty. It sits with the facilities that manufacture or process the products, renewed every two years,3 and a foreign facility's registration names a United States agent.7
| MoCRA duty | Who holds it | What you do as a reseller |
|---|---|---|
| Facility registration | Manufacturer or processor | Nothing, unless you repack |
| Product listing with ingredients | Label-named responsible person | Confirm listings cover the SKUs you order |
| Safety substantiation records | Responsible person | Nothing, if you sell unchanged |
| Serious adverse event report within 15 business days | Responsible person4 | Pass any customer report on the same day |
| US contact on the label for adverse events | Responsible person8 | Check the pack or sticker before sale |
The common mistake is the sticker. A US distributor that adds "Distributed by" with its own name to the pack becomes the responsible person, with listing and reporting duties.2 Decide that deliberately, not by accident at the labelling stage. Before the first order, agree in writing with the brand who holds listing and adverse-event intake for each SKU you plan to sell.
What makes a skincare product a drug in the US?
Its intended use, shown by its claims. A cosmetic cleanses, beautifies or alters the appearance; a drug is intended to treat or prevent disease or to affect the structure or function of the body.9 FDA establishes intended use from label claims, advertising, websites and promotional material, and from ingredients.9 So your shelf talker, Instagram caption and treatment-room script all count.
| Keep (cosmetic) | Avoid (drug territory) |
|---|---|
| "Moisturises and softens" | "Repairs the skin barrier" |
| "Smooths the look of fine lines" | "Regenerates cells"9 |
| "Leaves skin looking more even" | "Reduces melanin" or "lightens pigmentation"9 |
| "Fragrance-free, for skin that dislikes scent" | "Treats sensitive or reactive skin" |
| "Use morning and evening" | "Daily sun protection" (sun claims make it a drug)9 |
Product names count as labelling too. Have your regulatory adviser review any name or description that suggests a change in skin structure before you list it online.
Why should a US order leave out sunscreen?
Because sunscreen is a drug in the US. FDA regulates sunscreens as drugs that must meet the safety and efficacy standards for nonprescription products.5 A mineral SPF that is a cosmetic in the EU is not, by crossing the Atlantic, a compliant US OTC drug. Moisturisers and makeup marketed with sun-protection claims are cosmetic-drug combinations for the same reason.9
Endless Pure's SPF50 sticks therefore stay out of US orders. Source SPF from a US-compliant supplier, and keep sun claims off every French product you sell, including day creams.
How does a shipment clear US customs now?
With an entry, every time.1
You may file entries yourself: an importer transacting customs business solely on its own account needs no broker licence.10 Most small buyers still let a licensed broker file: the fee is small next to the cost of a misclassified line. Give the broker the commercial invoice, HTS heading 3304, which covers preparations for the care of the skin,11 and the country of origin per product, then let them quote the duty rate in force on the day.
What else should you check on the pack?
English labelling, US net-quantity units and the MoCRA contact. FDA requires label statements in English, net contents in US units (ounces or fluid ounces, with metric optional) and ingredients in descending order of predominance.12 MoCRA adds a domestic address, domestic phone number or electronic contact, which may be a website, through which the responsible person receives adverse event reports.8 Plan for a US sticker if the EU pack lacks any of these.
Two details work in your favour. MoCRA will require fragrance allergens on the label once FDA sets the list by regulation,8 and EU packs already name them where they are present. And "organic" needs care: the term is governed by USDA's National Organic Program, not FDA.13 Describe the certified products as "COSMOS certified by ECOCERT" rather than writing "organic" on your own US copy; the Eye Renewal Patches are not COSMOS certified, so leave the phrase off their card.
How does Endless Pure work with US partners?
On the standard terms published on the supplier fact sheet. Each order is produced as a fresh batch, with production time depending on the order volume, and leaves with tracking. Pay by card or SEPA bank transfer; there is no annual contract.
A US first order works best built around the lines that carry cosmetic claims easily: Bio-Retinol Serum and Elixir for the anti-age conversation, PURE CALM Light Moisturiser and Night Recovery Cream as the fragrance-free option, Hyaluronic Double Hydration Gel and Eye Renewal Patches for the treatment-room add-on. Product information is available to partners; review the EU claim wording for US use before you reuse it. Discovery Kits ship within the EU only, so a US buyer tests with a mixed order at the minimum, as described in testing a brand before a wholesale order.
Customs mechanics for every non-EU zone are in shipping outside the EU; the zone-by-zone overview is in French skincare wholesale for international retailers.
Frequently asked questions
Do I need FDA approval to sell imported French skincare in my spa?
Does my store become the MoCRA responsible person if I import European cosmetics?
Not if you resell the products unchanged under the brand's label. You become it once your company's name goes on the label as manufacturer, packer or distributor.2
Can I import European sunscreen to sell in the US?
Not as a simple cosmetic import. In the US sunscreens are regulated as drugs and must meet nonprescription drug standards, so a European SPF product needs to be compliant as a US OTC drug before it can be sold.5
Is there still a duty-free limit for small skincare orders shipped to the US?
No. Commercial terms are available in your trade account once your business is verified.1
Can I write 'organic' on US shelf cards for COSMOS Organic skincare?
Be careful. FDA does not define 'organic'; the term is governed by USDA's National Organic Program, and a cosmetic making an organic claim must meet both USDA and FDA rules.13 'COSMOS certified by ECOCERT' describes the certification without making a USDA claim.
Can I import Endless Pure SPF50 sticks into the USA?
No, leave them out of US orders. Sunscreens are drugs in the US, so order the cleansers, serums, moisturisers and eye care, and source SPF from a US-compliant supplier.
Sources
- US Customs and Border Protection, Federal Register, Indefinite Suspension of the De Minimis Exemption for Merchandise Arriving Through All Modes Other Than the International Postal Network (interim final rule, 24 June 2026) (2026). www.federalregister.gov Checked 2026-10-22.
- Legal Information Institute, Cornell Law School, 21 U.S. Code § 364 – Definitions (responsible person, serious adverse event) (2022). www.law.cornell.edu Checked 2026-10-22.
- US Food and Drug Administration, Registration and Listing of Cosmetic Product Facilities and Products (2026). www.fda.gov Checked 2026-10-22.
- Legal Information Institute, Cornell Law School, 21 U.S. Code § 364a – Adverse events (2022). www.law.cornell.edu Checked 2026-10-22.
- US Food and Drug Administration, Sunscreen: How to Help Protect Your Skin from the Sun (2024). www.fda.gov Checked 2026-10-22.
- US Food and Drug Administration, Modernization of Cosmetics Regulation Act of 2022 (MoCRA) (2026). www.fda.gov Checked 2026-10-22.
- Legal Information Institute, Cornell Law School, 21 U.S. Code § 364c – Registration and product listing (2022). www.law.cornell.edu Checked 2026-10-22.
- Legal Information Institute, Cornell Law School, 21 U.S. Code § 364e – Labeling (2022). www.law.cornell.edu Checked 2026-10-22.
- US Food and Drug Administration, Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?) (2022). www.fda.gov Checked 2026-10-22.
- Electronic Code of Federal Regulations, 19 CFR 111.2 – License and district permit required (2026). www.ecfr.gov Checked 2026-10-22.
- US International Trade Commission, Harmonized Tariff Schedule of the United States, heading 3304 (beauty or make-up preparations and preparations for the care of the skin) (2026). hts.usitc.gov Checked 2026-10-22.
- US Food and Drug Administration, Cosmetics Labeling Guide (2022). www.fda.gov Checked 2026-10-22.
- US Food and Drug Administration, Organic Cosmetics (2022). www.fda.gov Checked 2026-10-22.