Selling Cosmetics on Marketplaces: Category Approval and Required Documents

Opening a cosmetics category on a marketplace is not a matter of "filling out a form". When a platform asks you for documents, it is really asking one single question: who is legally accountable for this product? Any seller who cannot answer that clearly will sooner or later have their listing suspended. Define your role first; the document set will follow naturally.

In Turkey, placing cosmetic products on the market is governed by Cosmetics Act No. 5324 and the Cosmetics Products Regulation. Under the Act, notification to the Ministry of Health is mandatory before a cosmetic product is first placed on the market; any subsequent changes to the product or manufacturer must also be notified. This notification is made through ÜTS (Product Tracking System).

The critical distinction is this: the process (notification steps, data entry into the system) and responsibility (the person legally accountable for the product's safety) are not the same thing. All responsibilities set out in the relevant legislation concerning notified cosmetic products rest with the responsible person. In other words, your accountant or consultant may carry out the notification; the responsibility is yours.

Once you have correctly defined your role, your document file is no longer a mere "list" — it becomes a defence file. The rest is your signature.

Sellers commonly assume: if my store is approved, I can sell anything. Not so. Store approval is the commercial identity gate; category approval is the product compliance gate. Cosmetics, fragrances and personal care sit behind that second gate.

Documents required at store opening vary by company type. Across all company types, the general requirements are a current tax certificate, a signature declaration or signatory circular, bank IBAN details and ID. For limited liability and joint-stock companies, a trade registry gazette, an activity certificate issued within the last six months, a MERSİS number and a KEP (registered electronic mail) address are also required. Document currency matters too: the activity certificate must have been issued within the last six months, and the tax certificate must show the current year.

On the category side, things change. Platforms require activity, brand, authorisation, permit or product safety documents depending on the category. If you are selling under your own brand, a trademark registration certificate is required; for categories such as cosmetics, food or toys, the relevant certificates may also be requested.

The claim circulating online that "cosmetic notification is free" is outdated. From 28 May 2024, an assessment (tahakkuk) process has been applied to company, document and product applications relating to cosmetics. The relevant fee information is tracked via the "Institutional Services Price Tariff" document published on the Authority's website. The tariff is updated annually; plan your budget on a yearly basis.

The correct order is: legal identity first, then product registration, then the marketplace panel. Sellers who get the order wrong try to gather documents after uploading their products — and their listings get locked in the meantime.

You have prepared your documents and your category is open. Now the real risk begins: copy. Every claim you make in a product description counts as evidence at inspection. When the top note fades, this layer takes the stage — and this layer is the legal layer.

Writing "EDP" on a product page is not a marketing label — it is a declaration. But you also need to communicate the following to consumers accurately: the percentage alone does not determine performance. What matters is the volatility of the raw materials. A citrus-forward 25% extrait may dissipate quickly, while a 10% formula built around amber–musk–resin may linger on skin for hours. Rather than promising an absolute number of hours on your page, describe the structure of the formula.

The same rigour applies to the net quantity declaration. Marketplaces require a volumetric (ml) declaration, yet production fills by weight. The specific gravities of fragrance oils and solvents vary considerably — dropping to around 0.84 for citrus oils and rising above 1.10 for heavy resins and some synthetics. If you label a product as 50 ml but fill 50 g, in a blend with a density of 0.88 you are actually putting approximately 57 ml into the bottle; in the reverse situation you underfill. Underfill is the quietest source of consumer complaints and penalty risk. Calculate the fill target separately for each formula using volume × density.

Fragrances containing high-proof ethanol and room fragrance solvents such as DPM and MMB are flammable (low flash point). This affects both your production workshop and your shipping process. Before listing on a marketplace, obtain written confirmation from your courier that they transport this product group; otherwise you will make sales you cannot dispatch. On the production side, good ventilation, avoidance of static electricity and use of protective equipment (gloves, goggles) are non-negotiable.

When a listing gets locked, panic halts production. Yet the solution is almost always the same: upload the right document, in the right format, through the right channel. First, the three steps for crisis moments; then the most frequently asked questions.

Category strategy, scent brief and collection architecture all converge in one place: knowing in advance what you are selling, with what documentation and with what promise. A brand that answers the question "is this product a leave-on cosmetic or a room fragrance?" at the brief stage will encounter no difficulties on either the ÜTS or marketplace side.