UK Cosmetics Regulation: Compliance & Guidance

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UK Cosmetics Regulation

Are you planning to sell your cosmetics in the UK ?

UK Cosmetic Regulations: The United Kingdom is an important market for cosmetic products in the world (valued at ±€10.5 billion at retail sales price). The United Kingdom is among the leading three cosmetic markets in Western Europe after Germany and France (and 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 the UK is often seen as the biggest Western Europe growth in the next years.

A regulation just as complicated as the EU.

The United Kingdom formally left the European Union on January 31, 2020 but the UK Cosmetic Regulations originates from the EU Cosmetic Regulations 1223/2009. Cosmetics companies had until December 31, 2020 (transition period) to comply with the requirements of the “The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, Schedule 34”, the so-called “UK Cosmetics Regulation”. Much legislation has been enacted over years to better protect consumers, animals and the environment, to better inform end users and to better harmonize national laws. As such, every cosmetic product available in the UK market, whether for payment or free of charge, needs to comply with a long list of legal requirements.

Before launching your brand in the UK, it’s crucial to make informed decisions that will impact your long-term success. We recommend selecting a qualified partner who can support your growth on both sides of the Channel. Biorius ensures your presence in both the EU and the UK by certifying that your products meet compliance standards in both territories.

Biorius, also specialist in UK cosmetics safety assessment.

With over 15 years of expertise in cosmetic safety assessments and EU Cosmetics Regulation, Biorius now extends its specialized services to include UK regulations. Our reliable turnkey solution for verifying and registering cosmetic products ensures compliance with both EU and UK standards.

Leveraging in-depth knowledge of legislation and supported by a team of over 50 scientific consultants, Biorius offers a comprehensive range of expertise and sophisticated IT tools. This makes us the fastest and most reliable way to access the UK market, ensuring your products meet all necessary regulatory requirements.

5 Steps to Achieve EU Cosmetics Compliance

Formula Review

Cosmetic Product Safety Report (CPSR)

SCPN Notification & Product Information File (PIF)

Labels & Claims Review

Legal Representation

Step 1: Formula Review

This first step includes the:

This step is a prerequisite for the preparation of the CPSR (Cosmetic Product Safety Report) and the verification of the product label.

The formula review is a meticulous review of your cosmetics formula to ensure that all ingredients are safe for their intended use and comply with the UK Cosmetics Regulation:

The review is based on the composition expressed in the raw materials trade names. The documentation of each raw material is reviewed to verify its regulatory compliance, and the impurities profile is highlighted.

Preliminary calculations and investigations are conducted to ensure that each ingredient and impurity is safe, given the cosmetic product type, its intended use and the targeted population.

A Formula Review can also be performed on its own, outside of our EU registration. Discover our Cosmetic Formula review service.

Step 2: Cosmetic Product Safety Report (CPSR)

The CPSR (Cosmetic Product Safety Report) is a comprehensive document produced by a qualified toxicologist. It intends to support and confirm the safe use of the cosmetic product, taking into consideration all pieces of information available, such as toxicological profiles of each ingredient and impurity, test results, certificates, declarations, raw materials documentation, etc.

The CPSR takes the form of two distinct sections, Part A and Part B.

Part A: Cosmetic Product Safety Information

This part of the report contains all the data needed for the evaluation of the cosmetic product.

Part B: Cosmetic Product Safety Assessment

This part of the report includes an evaluation of the cosmetic product’s safety and conclusions. The Part B is essential, as it certifies the effectiveness and safety of a product before being placed on the British market.

Introducing a cosmetic product to the UK market without a high-quality CPSR is a serious offensive that typically leads to withdrawal from the market, significant financial penalties and serious damage to the cosmetic brand’s reputation.

Our services specialize in guiding you through this process. We’ll help you assess your product’s ingredients, formulation, and intended use to ensure compliance with UK regulations. With our expertise, you can confidently bring your cosmetics to market while meeting all necessary safety requirements.

Step 3: Product Information File (PIF) and SCPN Notification

A PIF (Product Information File) is the complete cosmetic regulatory file that contains the:

A Product Information File (PIF) is an extensive and meticulously structured dossier containing all relevant information pertaining to a specific cosmetic product. This data encompasses various sources: some provided by product manufacturers, others by independent laboratories, and yet more by duly-qualified safety assessors. Read more about the Product Information File (PIF).

Upon the completion of the PIF, the cosmetic product becomes eligible for electronic notification to the British Portal, the so-called SCPN (Submit Cosmetic Product Notification) and a unique SCPN number is delivered. This identifier can be requested from both the importer and the Responsible Person at any given time, notably by customs officers.

Following Brexit, it’s essential to update Product Information Files to include the names of both the EU and UK Responsible Persons. Here’s what you need to know:

Dual Market Notification: Cosmetic products sold in both the EU and UK must be notified in both the CPNP (Cosmetic Products Notification Portal) and the SCPN (Submit Cosmetic Product Notification) to ensure compliance in both territories.
Labeling Requirements: The names and addresses of both the EU and UK Responsible Persons must be included on the product label if the product is sold in both markets.
Re-notification Process: Each product must be re-notified in the new UK notification system to be allowed for sale in the UK. There is no automatic transfer between the EU CPNP and the UK's SCPN. The British notification system, which became operational on January 1st, 2021, is similar to the CPNP. All cosmetic products already on the UK market had to be re-notified by March 31st, 2021.

With our expertise, we’ll guide you through to ensure smooth market access for your cosmetic products in both the EU and UK.

Step 4: Labels and Claims Review

Understanding UK cosmetic labelling rules can be challenging. While distributors ensure compliance, the design and creation of labels and packaging are significant investments for brand owners. Distributors can reject products that do not meet these requirements.

Clear labelling helps consumers make informed purchases and protects their health. All essential information must be easily accessible, readable, and understandable at the time of purchase. Consumers need to know exactly what they are buying when they examine the product.

A Label Review includes a thorough compliance check of packaging and labels, covering claims, Period After Opening (PAO), warnings, and the INCI list. The product label must also include the country of origin if manufactured outside the UK and the contact details of the UK Responsible Person on both primary and secondary packaging.

Conducting a Label Review in the UK ensures that your labels meet all UK Cosmetics Regulations. Consulting with a reputable company like Biorius ensures your labels are compliant.

Leverage Biorius’ regulatory expertise to review your labels and ensure compliance in both the EU and the UK post-Brexit.

Step 5: Legal Representation

The Legal Representation for cosmetics in the UK is designated as the Responsible Person. This role carries numerous responsibilities, and the Responsible Person assumes accountability in cases of non-compliance.

A straightforward explanation of the Responsible Person is:

A Responsible Person is designated in SCPN for each notified product. Among other important functions, this Responsible Person will ensure the compliance of the cosmetic products on an ongoing basis and will update the PIF when necessary.

We address any adverse effects and keep your Product Information File updated. Additionally, your brand can utilize our name and address on labels, allowing us to handle regulatory matters and consumer complaints on your behalf.

We recommend choosing a Responsible Person with offices in both the EU and the UK to represent your products in both regions. A Responsible Person will audit cosmetic product dossiers to ensure they comply with legislation, minimizing risks. This auditing process involves additional costs and time, making it more efficient to work with a single Responsible Person.

Biorius, with offices in both the EU and the UK, offers seamless representation and compliance services, serving as your Responsible Person in both areas.