Shellac Exporter to France — Gomme-Laque, E904 & INCI Guide

Three markets under one name

The rules are European, but the checks are French: the DGCCRF controls food and consumer products, and cosmetics must have a Responsible Person established in the EU. One Indian lot will not serve all three uses unless the file matches the use.

Confectionery, chocolate, chewing gum	E 904 / gomme-laque, glazing agent — wax-free bleached shellac, wax ≤ 0.2%.
Fresh fruit (citrus, apples)	Surface treatment — food-grade shellac in alcohol or ammonia solution.
Supplements & FSMP tablets	E 904 coating — wax-free, with the 2026/189 conditions for foods for special medical purposes.
Hair spray, mascara, eyeliner, gloss	INCI: SHELLAC — cosmetic-grade dewaxed bleached shellac.
Varnish, inks, packaging coatings	Gomme-laque or natural resin to an agreed specification; food-contact declaration where the coating touches food.
Wood finishing & restoration	Flakes and button lac for vernis au tampon (French polish) — technical grade, never sold as E904 or cosmetic.

Food: E 904 and French labelling

E 904 is authorised by Regulation (EC) No 1333/2008 with purity criteria in Regulation (EU) No 231/2012, both applying directly in France. On labels, the DGCCRF checks the INCO rules (Regulation (EU) No 1169/2011): the additive appears as E 904 or gomme-laque/shellac. Typical uses include chocolate and confectionery glazing, chewing gum, decorations, small chocolate-coated bakery items, nuts, coffee beans and the surface of certain fresh fruit.

Since Regulation (EU) 2026/189, the E 904 specification covers wax-free bleached shellac only (wax ≤ 0.2%), and E 904 is also allowed in tablet-form foods for special medical purposes at up to 46,000 mg/kg. A typical French buyer specification adds acid value, loss on drying, rosin absent and a lead limit — all on the batch COA.

Organic (bio) products: shellac is generally not an approved coating agent for EU organic processing. Check with the buyer's certifier before promising it for an AB specification.

Cosmetics: INCI SHELLAC

Cosmetics fall under Regulation (EC) No 1223/2009. The INCI name on the pack is SHELLAC (CAS 9000-59-3, EC 232-549-9). In France it is used mainly in hair sprays, mascara, eyeliner and gloss, as a film-former, binder and hair-fixing agent. Shellac is not on the prohibited list, so it falls under the general rules: the finished product must be shown to be safe, impurities controlled and claims honest.

The Indian supplier is not the Responsible Person — the French brand notifies the finished product on the CPNP and keeps the Product Information File (PIF) and safety report. But without the supplier's ingredient data, the Responsible Person cannot complete the file. French cosmetics buyers typically ask for:

• Specification and batch COA (Gardner colour, wax, acid value, loss on drying, heavy metals, identification)
• Process statement — dewaxing, and whether colour was removed physically or by chemical bleaching
• SDS in CLP format, in French or English
• INCI, CAS, insect-origin, non-GMO and allergen statements
• A statement that no animal testing was carried out for cosmetic purposes, in line with Regulation 1223/2009
• Residual solvent or chlorine data where the grade is chemically bleached
• Storage conditions — shellac polymerises and blocks in heat

Shellac comes from the lac insect (Kerria lacca), not from plants — "clean" and vegan brands will need that stated clearly.

Coatings, inks and food-contact materials

For varnishes and inks that touch food, the EU framework is Regulation (EC) No 1935/2004 with good manufacturing practice under Regulation (EC) No 2023/2006; plastics-specific rules apply only where the coated material is plastic. Buyers usually ask for a food-contact declaration based on composition and intended use. Do not mix files: an industrial coating lot without a food COA must never be relabelled as E 904 or INCI SHELLAC.

Which documents for which use

Food (E 904)	Batch COA vs 231/2012 · E 904 declaration (1333/2008, 231/2012, 2026/189 if FSMP) · SDS · origin and traceability · allergen/GMO · process declaration
Cosmetics (INCI SHELLAC)	Batch COA · INCI/1223/2009 statement · SDS · origin · animal-origin and non-animal-testing statements · impurity and process data
Coatings & food-contact	Specification · COA · SDS · origin · 1935/2004 food-contact declaration where the coating touches food
Wood finishing & technical	COA · TDS · SDS · certificate of origin

Shipping from India to France

• Ports: FOB Kolkata to Le Havre, Fos-Marseille or Dunkirk, usually with transshipment, then road or rail to Île-de-France, Lyon or the confectionery and cosmetics clusters. Air freight to Paris CDG suits samples and cosmetic lots.
• Terms: FOB Kolkata, CFR or CIF Le Havre.
• Classification: lac and shellac generally move under HS 1301.90 — agree the exact code with the French customs broker.
• Invoice wording: in French or English and matching the use — for example "dewaxed bleached shellac, food additive E 904" or "INCI SHELLAC". Never "industrial varnish" for a food or cosmetic lot. The DGCCRF may ask for the COA at the port on food consignments.
• Import: the French importer's EORI number on the declaration. Check duty in TARIC and do not assume India–EU trade-agreement benefits until they apply on your shipment date.

Grasse and the fragrance cluster

Grasse, in Provence-Alpes-Côte d'Azur, is one of Europe's best-known perfume centres, and France has a wider ecosystem of fragrance houses, aroma-chemical producers and fragrance R&D laboratories. That makes France a relevant market for aleuritic acid (CAS 533-87-9), a shellac-derived starting material for macrocyclic musk synthesis. We describe this as a potential buyer segment; synthesis routes, regulatory status and suitability for a given product are for the buyer to validate.

For aleuritic acid, French buyers typically ask for an SDS, a batch COA (assay, acid value, hydroxyl value, melting range and loss on drying), a certificate of origin and transport data. Under EU REACH, registration duties sit with the EU importer for substances imported at one tonne or more a year; we supply the composition data the registrant needs. Sea freight goes CIF Le Havre or Marseille-Fos, or to your nominated port, on quotation, and samples go by air courier.

What we supply to French buyers

Our strongest fit for France today is wood finishing, restoration and technical supply: shellac flakes and handmade button lac for vernis au tampon, and seedlac for refiners — each with a batch COA. For fragrance houses and aroma-chemical makers around Grasse we also supply aleuritic acid, a shellac-derived starting material for macrocyclic musks. For E 904 food or INCI cosmetic enquiries, state the grade and the file you need when you request a quote, and we will confirm what can be supplied and documented before we price it.

Quick answers

Is an E904 file enough for cosmetics? No. A cosmetics Responsible Person needs the INCI name SHELLAC, impurity and process data, and a statement under Regulation (EC) No 1223/2009. A cosmetics file also does not replace the Regulation 231/2012 criteria for food use.

Who notifies a shellac cosmetic on the CPNP? The Responsible Person for the finished cosmetic product, established in the EU. The Indian resin supplier provides the ingredient data but does not notify.

Is shellac vegan? No. Shellac is secreted by the lac insect, so it is not vegan. French clean-label and vegan brands usually use carnauba wax or a plant-based film instead.

This page summarises publicly available EU law and trade practice as of September 2026. Verify the current consolidated texts of Regulations 1333/2008, 231/2012, 2026/189, 1223/2009, 1935/2004 and 1169/2011, and TARIC duty, before ordering. It is not legal advice.