Transition period for cosmetic labels in the UK

The importance of the UK cosmetic market

A few words and key figures about the UK cosmetic market

The United Kingdom is among the leading three cosmetic markets in Western Europe after Germany and France followed by Italy and is the 8th biggest cosmetic industry in the world, behind the USA, China, Japan, India, Brazil, Germany and France.

The global cosmetics market size is projected to reach a growth of 25% by 2027 and, after a tough year 2020 with Covid-19, the UK is often seen as the biggest Western Europe growth in the next years.

For more information about the impact of Covid-19 crisis on the EU/UK Markets, please read our blog article here.

Brits love their skin. They are willing to pay to take care of it; the UK skincare is predicted to reach  around 22 billion euro by 2024. Suncare products still dominate the market and is expected to retain its dominance in the next years. Men’s grooming products are booming, taking more and more market shares and could be the next dominant product category.

UK cosmetic market: Brexit is our cup of tea

The UK is no longer a member of the European Union and although the UK Cosmetic Regulation originates from the EU Cosmetic Regulation 1223/2009 ; cosmetic brands have to take additional steps to gain compliance with the UK legislation Schedule 34 of The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 from January 1st, 2021.  The UK CR is applicable to cosmetics products placed on the market in Great Britain, which includes England, Scotland and Wales. Cosmetics products sold in Northern Ireland are still covered by the EU Cosmetics Regulation (EC) 1223/2009.

The main important changes due to the Brexit are:

  1. A UK Responsible Person with offices in UK must be appointed. The Responsible Person’s contact details have to be added the product label (primary and secondary).
  2. The country of origin has to be included on the product label if the product is manufactured outside of the UK.
  3. Each cosmetic products must be notified on the British Portal, the so-called SCPN (Submit Cosmetic Product Notification)

N.B: Another very important matter about the Brexit is that, although an EU CPNP notification can be transferred from one Responsible Person to another (for various reasons if a change of Responsible Person is necessary), this is not the case for the UK SCPN (Submit Cosmetic Product Notification) and a new notification will be necessary if the Responsible Person is changed (for various reasons).

For more information about the impact of Brexit on compliance in the UK, please read our blog article dedicated to this matter here.

The UK Responsible Person

The obligations of responsible persons are covered by Article 5 of the UK CR.  

On top of product conformity and safety, the roles of a responsible person are to:

  • Protect your brand against compliance issues
  • Assist you with legal questions related to the UK Cosmetics Regulation
  • Answer all questions from National Competent Authorities
  • Manage all inspections decided by the Supervisory Competent Authorities
  • Keep a close eye on regulatory developments and keeping you up to date
  • Handle all cosmetovigilance issues (undesirable effects) by following-up with the consumers and ensuring the best course of action

Our advice is simple: brands should invest time in finding a reliable partner to assist them with gaining compliance and acting as their Responsible Person. You will also find a comprehensive article on this matter here.

1 trusted partner, 2 regions

Biorius provides A-Z assistance with both the UK and European markets. We handle everything from the preparation of the PIF to the notification and the Legal Representation.

Our mission is simple: we offer a turnkey solution by alleviating your regulatory burden and reducing the time to market of your products.

For more information or help with this matter, please do not hesitate to contact us.

Nicolas Lenaers

Business Development Representative

nicolas.lenaers@biorius.com

Author

  • Frédéric Lebreux

    Dr. Frédéric Lebreux is Biorius's Chief Executive Officer and has worked in the cosmetic industry for more than 13 years. He is regularly invited as a speaker or Professor to cosmetic events.