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The short answer
Under the GB Cosmetics Regulation, the duties on a cosmetic product (Responsible Person, safety assessment, Product Information File, SCPN notification and labelling) attach when a finished product is made available to consumers. Bulk shea butter sold to a manufacturer to be formulated is a raw material: the manufacturer that turns it into a product carries those duties. Once you pack the same shea into jars and sell it for use on skin or hair, it is a cosmetic product and the full rules apply to you.
Many diaspora importers bring in Nigerian shea butter in bulk cartons. Some sell to soap makers and cosmetics companies; others repack it into small tubs for market stalls and online shops. The same product can sit on either side of the legal line, depending on who you sell it to and how.
What the law calls a cosmetic product
Article 2 of Regulation (EC) No 1223/2009, as it applies in Great Britain, defines a cosmetic product as any substance or mixture intended to be placed in contact with the external parts of the human body, including the skin, hair and nails, or the teeth and mouth, mainly to clean, perfume, change the appearance of, protect or keep them in good condition, or correct body odours. The same article defines "making available on the market" as supplying a cosmetic product for distribution, consumption or use on the GB market in the course of a commercial activity.
Two points follow. Shea butter can be a cosmetic on its own, because a single substance can qualify. And the test turns on what it is intended for: a carton sold to a factory as an ingredient is not being supplied to be put on someone's skin as it stands.
Three common situations
| What you do | Likely position | Who carries cosmetic duties |
|---|---|---|
| Sell 25kg cartons to UK cosmetics manufacturers as an ingredient | Raw material | The manufacturer, for the finished products it makes |
| Repack into 200g tubs labelled "pure shea body butter" and sell online | Cosmetic product | You, as importer or own-brand distributor |
| Sell bulk cartons to individual shoppers who use it on their skin | Likely a cosmetic product, because the buyer is a consumer using it as one | You |
These are general readings, not legal advice. If your case is borderline, ask your local Trading Standards service, which enforces cosmetics law.
If you sell as a raw material
- Describe it as a raw material or ingredient on invoices and specifications, and sell to businesses, not consumers.
- Expect your customers to ask for a specification, a certificate of analysis for each batch and information on origin and processing, because they need it for their own safety assessments.
- Keep batch traceability from the Nigerian supplier to your buyer.
- Chemicals rules may also apply to substances imported in quantity. Check with the Health and Safety Executive whether UK REACH affects your volumes.
If you sell as a cosmetic
The OPSS guidance (updated 16 October 2026) then applies in full: a UK-established Responsible Person, a safety assessment by a qualified assessor, a Product Information File kept for 10 years after the last batch, SCPN notification before sale, and a label showing the Responsible Person's UK address, country of origin, weight, date, batch, function and ingredients. See the Responsible Person guide and SCPN notification. Our earlier piece on shea butter and black soap rules covers retail labelling.
Signs you have crossed into cosmetic sales
The raw-material position depends on how you actually trade, not only on what your invoices say. You are moving toward selling a cosmetic product if you:
- sell to individuals rather than businesses, for example through marketplaces or social media;
- describe the product with consumer claims such as "moisturises", "for glowing skin" or "for hair growth";
- pack it in consumer sizes with usage directions;
- add fragrance, oils or other ingredients, which makes it a mixture you have formulated.
If any of these apply, plan for the full cosmetic rules or change how you sell.
Worked example: one importer, two channels
Example. Hauwa imports 2 tonnes of unrefined shea a year. She sells 1.6 tonnes in cartons to three UK soap makers, with batch certificates. She repacks the rest into tubs for her own online shop. The cartons are raw material sales; the tubs are cosmetic products for which she is the Responsible Person. She commissions one safety assessment for the tub product, notifies it on SCPN, and keeps the carton trade separate in her records so it is clear which batches went where.
Customs is the same either way
At the border the cosmetic question does not change the paperwork: you need a GB EORI number, the right commodity code and a declaration, and Nigeria's DCTS Enhanced tier may give 0% duty if an origin declaration is provided. See checking UK import duty.
Where Pryme fits
Paying shea cooperatives in naira and receiving sterling from UK buyers fits a Pryme Business Account: money stays in the currency it arrived in until you choose to convert.
Questions people ask
Is raw shea butter a cosmetic in the UK?
It depends on use. Sold to a manufacturer as an ingredient, it is a raw material. Sold to consumers to put on skin or hair, it is a cosmetic product.
Do I need a safety assessment to sell shea in 25kg cartons?
Not if you sell it to businesses as an ingredient. The manufacturer that makes the finished cosmetic needs the assessment.
Do I need SCPN to sell shea to soap makers?
No. SCPN notification is for cosmetic products made available to consumers, made by their Responsible Person.
Who decides if my product is a cosmetic?
The definition in the Cosmetics Regulation. Trading Standards enforces it and can advise on borderline cases.
Sources
- legislation.gov.uk: Regulation (EC) No 1223/2009 on cosmetic products, Article 2 definitions (GB version) · accessed Oct 2026
- GOV.UK (OPSS): Making cosmetic products available to consumers in Great Britain (updated 16 Oct 2026) · accessed Oct 2026
- GOV.UK (OPSS): Submit a cosmetic product notification (last updated 31 Dec 2020) · accessed Oct 2026
- GOV.UK: Preference tiers under the Developing Countries Trading Scheme (updated 19 Oct 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.