Step 2: Cosmetic Product Safety Report (CPSR)

The CPSR (Cosmetic Product Safety Report) A&B (signed by a Toxicologist) is a long and complex file of the UK Cosmetics Regulation.

The CPSR is a comprehensive document produced by a qualified toxicologist. This safety report 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. 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. Furthermore, it should be ensured that the CPSR are signed by qualified toxicologists with degrees recognized in the UK (for the UK market) and in the EU (for the EU market). Biorius has toxicologists recognized as qualified Safety Assessors on both sides of the Channel.

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 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 UK market.

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

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

• Formula
• CPSR A&B
• Labels

A Product Information File is a large and highly-structured dossier containing every piece of information related to a given cosmetic product. Some of the data come from product manufacturers, other data from independent laboratories, and yet other data comes from a duly-qualified safety assessor. Learn more about the Product Information File (PIF)

Once the PIF has been completed, the cosmetic product can be notified electronically on the British Portal, the so-called SCPN (Submit Cosmetic Product Notification) and a unique SCPN number is delivered. This number can be requested from the importer and the Responsible Person at any time, notably by customs officers.

In other words, a notification is to announce to the UK that you will sell a product in the United Kingdom.

Technically, cosmetic products are not registered in the UK; they are notified. Unlike other countries and regions that require pre-approval of the products by the competent authorities, the UK requires notification before the product can be launched in its market. This means that verification by the competent authorities is performed after the product is launched in the UK market. For this reason, selecting a qualified and competent Responsible Person is especially important.

After Brexit, Product Information Files must be updated to display the name of the EU and the UK Responsible Persons. Furthermore:

• Cosmetic products sold in both markets must be notified both in the CPNP AND the SCPN to enable you to market them in both territories
• EU and UK Responsible Persons’ names and addresses must be included on the label if the product is sold in both territories.

Each product has to be re-notified in a new notification system in order to be allowed for sale in the UK. No automatic transfer between the EU CPNP (Cosmetic Products Notification Portal) and this new British notification portal (SCPN: Submit Cosmetic Product Notification) has been developed. The British system was made available on January 1^st, 2021, and is relatively similar to CPNP. All cosmetic products currently for sale in the UK market had to be re-notified within 90 days from the end of the transition period (namely March 31^st, 2021).

Step 4: Labels and Claims Review

The UK cosmetic labelling rules may seem very confusing and although it falls under the responsibility of the distributors, the design and edition of labels and packaging are and remain a costly exercise for cosmetic brand owners.

The distributors are of course fully entitled to refuse products that would not comply with these requirements.

A clear label is important to help consumers for their purchases and to protect their health, all important information always has to be easily accessible, readable and understandable by the consumer at the time of purchase. The rule is actually quite simple: the end-consumer has to understand precisely what he is buying when he is checking the product.

A Label Review is a complete compliance of packaging and labels and the experts will check everything on the packaging and labels: claims, PAO (Period After Opening), warnings, INCI list, … .

The country of origin has also to be included on the product label if the product is manufactured outside of the UK. The UK Responsible Person’s contact details also have to be added on the product label (primary and secondary).

In summary, making a Label Review in UK (complete review and revision of labels and claims that take into account all UK Cosmetics Regulations) and a consultancy on specific claims or topics that the brand wants to promote as marketing text (by a recognized and renown company like Biorius) is the best idea for your business.

Using our regulatory expertise, Biorius reviews your labels to ensure their compliance in the EU and the UK after Brexit.

Step 5: Legal Representation

The Legal Representation for cosmetics in UK is called the UK Responsible Person. Since January 1^st, 2021, a Responsible Person in the UK is required in order to sell cosmetic products in the country. A cosmetics brand selling both in the EU and in the UK needs a local Responsible Person for each economic area.

The Responsible Person comes with many responsibilities and the Responsible Person will be held responsible in the event of a non-compliance problem.

A simple and easy way to explain the Responsible Person is:

• Who do the UK authorities (OPSS – Office Product Safety & Standards) have to call if they want to control your cosmetic product?
• Who should a consumer call if they have an unusual reaction to your cosmetic product?

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.

In short, being a Responsible Person implies many responsibilities and is an important and delicate matter that should not be taken lightly. Cosmetic brands should really invest time in this crucial step. Check out the best way to choose your Responsible Person

Learn more about Responsible Persons and their obligations

Among other recommendations, a cosmetics brand should try to find one Responsible Person with offices both in the EU and in the UK who can, therefore, represent products in both regions. A new Responsible Person will typically audit cosmetic product dossiers to ensure that they comply with the legislation and to avoid taking unreasonable risks. Such an audit comes with additional costs and takes time. For that reason, working with only one Responsible Person is the most cost-effective option for cosmetics brands. Biorius has offices in both the EU and the UK, allowing us to serve as Responsible Person in both areas.

If you wish to develop the sales of your cosmetic products in UK, this is something Biorius can help you with. Biorius can indeed support the complete UK cosmetics regulation process.

Biorius is:

• Specialized in cosmetic regulations in the United Kingdom, Europe, the United States, and in more than 60 countries.
• A Responsible Person in UK (and Europe).
• Mainly composed of 50 regulatory experts, specialists, toxicologists and scientists (chemists and biologists)
• Reassuring and comfortable: we have more than 1,500 international clients, we have already evaluated more than 100,000 products and we never had any compliance issues (fines, withdrawals of the market, etc.) in 15 years of existence.