AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Under EU Regulation (EC) No 1223/2009, a cosmetic product can only be sold in Italy if a responsible person established in the EU stands behind it; when you import it from Nigeria, that person is you, unless you appoint another EU-based business in writing. Before the first sale you need a safety assessment and product information file, an electronic notification on the Commission’s portal (CPNP), and a compliant label.
Nigerian black soap, shea creams, hair oils, edge control and body butters sell well to the Nigerian and wider African community in Italy. The goods may be legal and registered in Nigeria, but the moment you put them on sale in Italy they are cosmetic products under EU law. The rules sit in one regulation that applies across the EU, Regulation (EC) No 1223/2009, and they put the duties on a named person rather than on the product.
Is your product a cosmetic?
Article 2(1)(a) of the regulation defines a cosmetic product as a substance or mixture intended to be placed in contact with the external parts of the human body (or the teeth and the lining of the mouth), mainly to clean, perfume, change appearance, protect, keep in good condition or correct body odours. Soaps, lotions, hair products, lip balms, perfumes and make-up are all in. Anything swallowed, inhaled, injected or implanted is not.
What you claim matters. A cream sold as a treatment for eczema or a hair oil that promises to cure alopecia may stop being a cosmetic and be treated as a medicine. Keep the claims to what a cosmetic does. Raw shea butter is a special case, because it can also be sold as food; see shea butter: food or cosmetic.
The responsible person: usually you
Article 4(1) says only cosmetics with a designated responsible person within the EU may be placed on the market. Article 4(5) makes each importer the responsible person for the products it imports. The regulation lets an importer appoint another person established in the EU by written mandate, which that person must accept in writing. Some small importers use a specialist service for this; whoever it is, their name and address go on the label and they carry the legal duties.
What the responsible person must have before the first sale
- Safety assessment. Article 10 requires a safety assessment and a cosmetic product safety report, set up under Annex I, before the product is placed on the market, kept up to date afterwards. In practice this needs a qualified assessor and the full formula from your Nigerian maker.
- Product information file. Article 11 requires a file for each product, kept for ten years after the last batch is placed on the market, in a language the Italian authorities can easily understand.
- CPNP notification. Article 13 requires the responsible person to notify the Commission electronically before sale: product category and name, responsible person, country of origin for imports, the member state of first sale, the frame formulation, any nanomaterials and any CMR substances of category 1A or 1B, plus the original label. Products containing nanomaterials have a separate notice six months before sale under Article 16(3).
- Labelling. Article 19(1) requires, among other things, the responsible person’s name and address, a batch number or product reference, and an ingredients list. A date of minimum durability is not needed where the product lasts more than 30 months.
The ingredient problem: what is legal in Lagos may not be legal in Milan
Nigerian and EU rules differ on some ingredients. A NAFDAC coordinator told NAN in July 2025 that hydroquinone is approved in cosmetics in Nigeria only up to two per cent. Under the EU-derived rules, a UK product safety report of 19 June 2024 describes hydroquinone as prohibited in cosmetic products, records a lightening lotion as failing Regulation 1223/2009, and says the import was refused at the border and destroyed. Treat any lightening, toning or “glow” product with suspicion and ask for a full ingredients list before you order.
- Ask the maker for the full formula with percentages; a label alone is not enough for the safety assessor.
- Check every ingredient against the regulation’s annexes of prohibited and restricted substances.
- Avoid products whose claims are medical.
- Ask for batch numbers and a certificate of analysis for each shipment.
Getting the goods into Italy
Cosmetics are commercial goods, so the import needs a customs declaration. Your business needs an EORI number, which for an Italian business is IT followed by its partita IVA; see getting an EORI number. Most small importers hand the declaration to a spedizioniere doganale, who will want the commercial invoice, packing list and transport document. On the Nigerian side, NAFDAC’s 2018 export guideline lists a combined certificate of manufacture and free sale for registered cosmetics, which is useful evidence that the maker is real.
A worked example
Example only: a Turin shop wants to sell three Nigerian products, a black soap, a shea body butter and a hair oil. It becomes the responsible person, collects the formulas from the Lagos maker, pays a safety assessor for three reports, builds three product files, notifies three products on CPNP and prints Italian over-labels with its own name and address and a batch number. Only then does it place the first order on sale. If the maker changes the formula, the report and the notification must be updated before the new batch is sold.
What to check first
- Who will be the responsible person, and do they accept the role in writing?
- Do you have the full formula and a safety report for each product?
- Is each product notified on CPNP before the first sale?
- Does the label carry the responsible person, batch number and ingredients, in the language Italy requires?
Where Pryme fits
When you pay the Lagos maker, a Pryme Business Account lets you hold euros and naira side by side and pay from the app; the rate and the fee appear before you approve. A verifiable receipt of each payment helps tie a batch to its invoice in your product file. Outside Nigeria, Pryme works through regulated partners. For paying suppliers in general, see paying a Nigerian supplier from an Italian account.
Questions people ask
Can I sell Nigerian creams in Italy if they have a NAFDAC number?
A NAFDAC number shows Nigerian registration only. In Italy the EU Cosmetics Regulation applies: a responsible person in the EU, a safety report, a product file, CPNP notification and a compliant label.
Who is the responsible person for imported cosmetics?
The importer, under Article 4(5) of Regulation 1223/2009, unless it appoints another EU-established person by written mandate that the person accepts in writing.
Is hydroquinone allowed in cosmetics in Italy?
A UK safety report under the same regulation text describes hydroquinone as prohibited in cosmetic products and records an import destroyed at the border. Do not import products containing it.
Do I need to notify every product on CPNP?
Yes. Article 13 requires notification of each cosmetic product before it is placed on the market, including the country of origin for imports.
Sources
- EUR-Lex: Regulation (EC) No 1223/2009 on cosmetic products (consolidated) · accessed Oct 2026
- GOV.UK: Product safety report, Caro White lightening lotion (19 Jun 2024) · accessed Oct 2026
- NAN: NAFDAC warns against use of excess hydroquinone in cosmetics (2 Jul 2025) · accessed Oct 2026
- partitaiva.it: Codice EORI, cos’è, a cosa serve, richiesta e verifica (1 Mar 2023) · accessed Oct 2026
- NAFDAC: Guideline for export of NAFDAC regulated products (2018, PDF) · 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.