A wholesaler sends photographs, the margin looks good, and the only thing standing between you and a first order is whether the product can legally sit on a shelf in this country. The label answers that, and it answers it before you pay rather than after. New Zealand publishes its cosmetic rules as a group standard issued by the Environmental Protection Authority, and the labelling conditions in it are specific enough to check from a photograph. This guide walks through them in the order you would read a bottle, then covers the clause that decides whether an imported label needs replacing at all. For anyone assembling a first stock float, I am Beezy pays you for consulting content in the app, which is a slow but debt-free way to fund an opening order.
Which rules actually apply to a cosmetic sold in New Zealand?
The Group Standard, and what it covers
The instrument is the Cosmetic Products Group Standard 2020, HSNO approval number HSR002552, issued by the Environmental Protection Authority under section 96B of the Hazardous Substances and New Organisms Act 1996. It came into force on 30 April 2021. It applies to any substance imported or manufactured for use as a cosmetic product where that product classifies as hazardous under the Hazardous Substances (Hazard Classification) Notice 2020, which covers a great deal more everyday skincare and haircare than the word hazardous suggests.
What sits outside it
The standard expressly excludes any substance intended to be ingested, inhaled, injected or implanted into the human body. It excludes products containing asbestos or a persistent organic pollutant, and products containing a component banned by the International Fragrance Association code of practice. Aerosol dispensers are capped at 1,000 millilitres water capacity. If a supplier is offering something that crosses one of those lines, the labelling question never arises, because the product is outside the standard entirely.
Check you are reading the current version
Group standards are amended, and the Environmental Protection Authority publishes consolidated versions on its own cosmetics page. Before relying on any clause for a commercial decision, open the Authority's cosmetics guidance and confirm which consolidated text is in force on the date you are ordering. The clause numbers quoted below are those of the 2020 standard.
What has to be on the label
The ingredient list, in a fixed order
This is the clause that catches most imports, because the order is prescribed rather than left to the manufacturer. Ingredients other than colour additives present at 1% or more must be listed in descending order by volume or mass. Ingredients other than colour additives present at less than 1% may then follow in any order. Colour additives come next, in any order. Flavours must be described either by the words flavour, flavours, aroma or aromas, or by their ingredients. Fragrances must be described by the words fragrance, fragrances, parfum or parfums, or by their ingredients.
The batch or source code
A label must provide the manufacturer's original source or batch code information. It is a short requirement and an easy one to fail, particularly on relabelled or repacked stock where the original code has been covered by a distributor's sticker. If you cannot find a batch code in the supplier's photographs, ask for one before ordering, not after the pallet lands.
Nanomaterials, spelled out
All ingredients present in the form of nanomaterials must be clearly indicated in the ingredient list, with the name followed by the word nano in brackets. The standard also carries a separate notification duty to the Authority for cosmetic products containing nanomaterials, so a product in this category is a heavier commitment than it looks on a spec sheet.
| Requirement | What the standard says |
|---|---|
| Ingredients at 1% or more | Descending order by volume or mass, colour additives excluded |
| Ingredients under 1% | Any order, colour additives excluded |
| Colour additives | Listed after the above, in any order |
| Flavours | Words flavour, flavours, aroma or aromas, or the ingredients |
| Fragrances | Words fragrance, fragrances, parfum or parfums, or the ingredients |
| Batch information | Manufacturer's original source or batch code |
| Nanomaterials | Name followed by nano in brackets |
| Ingredient naming | Common chemical names or International Nomenclature Cosmetic Ingredient names |
Where the ingredient list is allowed to live
Four permitted locations
The list does not have to be printed on the container itself. The standard allows it on the substance label, on the outer container or carton where the substance is packed in a primary pack, on a package insert or leaflet where the package is too small to carry the detail, or on a leaflet at the point of sale. That flexibility is commercially useful: a small imported bottle with a crowded label can be brought into line with an insert rather than a reprint.
The eighty square centimetre exception
Products displayed for sale in tightly compartmentalised trays or racks, or used with display units, may declare their ingredients in off-package labelling attached to the display rather than on each retail unit, provided the total surface area of the substance is less than eighty square centimetres. The exception does not apply to substances contained in a primary pack. If you sell lip balms or sachets from a counter display, this is the clause you are relying on.
What this means for your packaging decision
Read the four permitted locations as a cost ladder rather than as a list of equal options. Printing the list on the container is the most durable and the most expensive to change; a carton works only where the product ships in a primary pack, and disappears the moment a customer picks the bottle up on its own; an insert survives being separated from the display but not being thrown away; and a point-of-sale leaflet vanishes entirely if the product moves to a market stall or an online order. Choose the location that still works in the way you actually sell, not the one that is cheapest at the moment you order. A retailer who starts in a shop and later ships direct will need the information travelling with the product.
Free samples and testers
The labelling condition does not apply to free samples or testers. Worth knowing before you spend money relabelling a box of sachets you intend to give away.
The clause that decides whether an import needs relabelling
Australia, the United States, Canada or the European Union
The standard contains an alternative compliance provision, and for an importer it is the single most valuable sentence in the document. The ingredient list and schedule labelling requirements do not need to be met if the labelling complies with the current cosmetic labelling requirements of Australia, the United States of America, Canada or the European Union, as if the substance were for sale or supply in those countries. An imported product already labelled to European Union cosmetic rules can therefore go on a New Zealand shelf without a relabelling exercise. Note which jurisdictions are named, and which are not: a label built for a market outside that list does not get the benefit of the clause.
Sunscreen has its own route
A primary sunscreen may instead be labelled in accordance with the Australian Therapeutic Goods Order No. 69, the general requirements for labels for medicines. If sunscreen is part of your range, that is a different compliance path from the rest of the order and should be quoted separately by your supplier.
What alternative compliance does not excuse
The provision is about labelling, not content. A product whose formulation contains a component the schedules prohibit, or a restricted component outside its permitted conditions, is not rescued by a compliant European label. The schedules cover components that must not be present, components allowed only under stated restrictions, colouring agents, preservatives and ultraviolet filters. Ask your supplier for the full ingredient declaration in writing and check it against those schedules before the label question arises at all.
Building a first stock float with I am Beezy
What a few hundred dollars actually buys
Most first orders fail on cash rather than on compliance: the supplier wants a minimum quantity, and the minimum is larger than the money available. On I am Beezy the unit of income is a single consultation: a video watched, an article read, an advertisement viewed, with the amount attached to it settled to your usual payment method. Earnings run in the range of 5 to 15 euros a day across the platform, which at the European Central Bank reference rate of 1 euro to 1.9680 New Zealand dollars on 5 August 2026 is around NZ$10 to NZ$30 a day. Rates move, so confirm the conversion when the amount matters.
What it does not fix
It funds a sample order, not a container. And it is income like any other here, taxed from the first dollar under the Inland Revenue scale, which begins at 10.5% with no tax-free band. If your resale turnover reaches $60,000 over twelve months, or you expect it will over the next twelve, goods and services tax registration becomes compulsory at the 15% rate.
What do you check before you pay for a pallet?
Five things on the label
Work from photographs at sufficient resolution to read the small print, and refuse to proceed on a supplier's assurance alone. Look for an ingredient list that exists somewhere permitted; an order that puts the ingredients at 1% and above in descending sequence before the rest; a batch or source code from the manufacturer rather than the distributor; any nanomaterial marked with nano in brackets; and, if the product was made for another market, a label built for Australia, the United States, Canada or the European Union. Those five take about a minute each. If the images will not resolve, ask for a single sample unit to be couriered before the order is placed, and treat the courier fee as the cheapest part of the whole exercise.
Two things on the invoice
Ask whether the wholesale price includes goods and services tax at 15%, and ask what the terms are if a line has to be withdrawn from sale. A supplier who will not answer the second question in writing is telling you where the risk sits.
One thing about the claims
The Commerce Commission is New Zealand's competition and consumer regulator, and misleading claims about a product are its territory. A label whose ingredient list is impeccable but whose front panel promises a result the formulation cannot deliver is still a problem, and it is your problem once you are the one selling it.
| Check | Pass looks like |
|---|---|
| Ingredient list present | On pack, carton, insert or point-of-sale leaflet |
| Order of ingredients | 1% and above in descending order, then under 1%, then colours |
| Batch code | Manufacturer's original code, not covered by a distributor sticker |
| Nano ingredients | Marked with nano in brackets, and notification considered |
| Alternative compliance | Label built for Australia, USA, Canada or the EU |
| Formulation | Full declaration checked against the schedules |
| Front panel claims | Nothing you could not defend to the Commerce Commission |
None of this takes long once you have done it twice, and it is far cheaper than discovering the problem when the stock is already in a spare room. Print the checklist, send it to your supplier before the first order, and keep the replies. If the opening order is the part you are still short of, a fortnight of app earnings through I am Beezy is a plain way to put the sample order together without taking on credit.
