UK Cosmetics Compliance: Brexit impact

Are you Brexit ready?

Brexit will for sure impact the cosmetic industry and a quick reaction from cosmetic brands is required.

What are the key points for you as a cosmetic company?

Following a series of internal political issues, the United Kingdom has been forced to negotiate a new Brexit extension. Based on the new conditions, the UK is expected to leave the European Union on January 31st, 2020 with a possibility for the UK to leave earlier in case an agreement is found. However, general elections are scheduled in the UK on December 12th, 2019 and the result of this vote may deeply influence the current situation. Indeed, it has been recognized that a new United Kingdom European Union membership referendum may be organized in case the British Labour Party wins the election.

Different surveys are showing that a lot of cosmetic companies are not prepared for the upcoming event. Whatever may come next in the UK, the preparation is essential in order to avoid repercussions on your business. Therefore, we advise you to take precautions by ensuring your compliance.

Planning products relabelling and organizing requirements based on the EU and UK regulations are important actions definitely needed. In the event of a hard BREXIT, cosmetic companies would have to be fully compliant on January 31st, 2020.

To be ready for this scenario and under uncertainty, we advise you to consider this option and to take precautions from now on to keep selling your products on both sides of the Channel.

BIORIUS will gladly assist you with the different steps. We are pleased to remind you that we established a subsidiary in the UK in order to represent your products both in the EU and in the UK.

Which actions to undertake?

  • UK Responsible Person:

Appoint a Responsible Person in the UK if you are selling cosmetic products in this country.
Don’t worry, BIORIUS can play this role!

  • Labelling Review:

–      Responsible Person’s contact details: Feature the name and address of your UK Responsible Person on your product label.

–      Made in: Specify the manufacturing country for imported products.

·         If you are selling in the EU while manufacturing in the UK, the mention “made in the UK” will have to be displayed on your packaging.

·         If you are selling in the UK while manufacturing in the EU, the mention “made in the EU” will have to be displayed on your packaging.

  • Notifications:

Each product placed on the UK market will have to be notified on the UK Notification Portal within 90 days following the Brexit day. BIORIUS can take care of this duty and we invite you to contact your Account Manager once the Brexit took place.

Furthermore, if the current Responsible Person is based in the UK and the product is sold in the EU, the CPNP Notification should be transferred to another Responsible Person located within the EU by January 31st at the latest.

All CPNP Notifications still under a UK Responsible Person by January 31st will be null and void.

Companies failing to ensure the proper transfer of these notifications will have to repeat the notification exercise in the EU at their own expense.

Any questions?