Cosmetic regulation EU and UK requirements changed significantly after Brexit, although both markets still share a similar regulatory basis.
Although UK legislation maintains a structure very similar to the European Regulation, companies that market cosmetic products in both markets must now manage separate obligations.
The main change is not only in the legal text, but in the practical way compliance is demonstrated: different Responsible Persons, different notification systems, specific labelling requirements and special attention to the distinction between Great Britain and Northern Ireland.
For manufacturers, brands and importers, this means that a product compliant in the European Union is not automatically ready to be marketed in the United Kingdom. And vice versa. Because, apparently, selling a moisturising cream needed to become a small international administrative expedition.
Cosmetic Regulation EU and UK: Two Different Frameworks
In the European Union, cosmetic products are regulated by Regulation (EC) No 1223/2009, which establishes requirements for safety, composition, assessment, labelling, notification and market surveillance.
This Regulation applies in the EU Member States and establishes a harmonised framework. Once a product complies with European requirements and is correctly notified in the Cosmetic Products Notification Portal (CPNP), it can be marketed in the European market without needing to repeat the notification in each country.
In the United Kingdom, after Brexit, the framework applicable to Great Britain is based on the retained European cosmetics regulation, as amended by UK legislation. In practice, the requirements remain similar in many respects, but they are managed through a separate system and with specific obligations for the British market.
It is important to distinguish between:
- European Union: applies Regulation (EC) No 1223/2009.
- Great Britain: England, Scotland and Wales, with specific UK requirements.
- Northern Ireland: maintains a particular regime and, for cosmetics, remains linked to the rules applicable under the European framework.
This distinction is essential in order to define the regulatory strategy correctly.
Responsible Person: one of the most important changes
Both in the European Union and in the United Kingdom, every cosmetic product must have a Responsible Person before being placed on the market.
The Responsible Person is responsible for ensuring that the product complies with the applicable requirements. Their obligations include:
- Ensuring that a valid safety assessment is available.
- Keeping the Product Information File available.
- Ensuring compliance with labelling requirements.
- Completing the notification in the corresponding portal.
- Cooperating with the competent authorities.
- Managing information on undesirable effects.
- Taking corrective action when necessary.
Responsible Person in the European Union
To market a cosmetic product in the EU, the Responsible Person must be established within the European Union.
This may be:
- The manufacturer, if established in the EU.
- The importer, when the product comes from a third country.
- A distributor, if they market the product under their own name or modify the product in a way that may affect compliance.
- A third party appointed by written mandate.
The address of the Responsible Person must appear on the product label.
Responsible Person in Great Britain
To market cosmetic products in Great Britain, there must be a valid Responsible Person for the British market.
This means that a European Union brand wishing to sell in England, Scotland or Wales may need to appoint a specific Responsible Person for the United Kingdom and adapt its documentation and labelling to this market.
The UK Responsible Person must ensure compliance with the applicable GB requirements and complete the corresponding notification in the British system.
Northern Ireland: the case that should not be ignored
Northern Ireland should not automatically be treated in the same way as Great Britain.
Products intended for the Northern Ireland market must comply with the rules applicable under the European framework. As a result, they may require a Responsible Person established in the EU or in Northern Ireland and notification through the CPNP.
If a company markets products in the EU, Great Britain and Northern Ireland, it may need to manage more than one regulatory obligation. This is one of those points where assuming “United Kingdom = one single procedure” can become expensive.
Notification: CPNP versus SCPN
Pre-market notification is another point where the paths diverge.
CPNP in the European Union
In the EU, cosmetic products must be notified in the Cosmetic Products Notification Portal (CPNP) before being placed on the market.
The notification includes information such as:
- Product identification.
- Cosmetic product category.
- Responsible Person details.
- Country of origin, where applicable.
- Member State of first placing on the market.
- Presence of nanomaterials, where applicable.
- Frame formulation or composition.
- Labelling.
- Information required by poison centres and authorities.
Notification in the CPNP is not a prior authorisation. It is a mandatory communication that allows authorities and poison centres to access relevant information about the product.
SCPN in Great Britain
In Great Britain, cosmetic products must be notified through the Submit Cosmetic Product Notification (SCPN) system.
This system is independent from the CPNP. Therefore, a notification completed in the European Union does not replace the obligation to notify the product in the United Kingdom if it is going to be marketed in Great Britain.
Likewise, a notification in the SCPN does not automatically allow the product to be marketed in the European Union.
For companies operating in both markets, this means duplicating part of the regulatory work and ensuring that the information submitted in both systems is consistent.
CPSR, PIF and safety assessment
Safety assessment remains a central element in both markets.
In the European Union, the product must have a Cosmetic Product Safety Report (CPSR) prepared in accordance with Annex I of Regulation (EC) No 1223/2009.
The CPSR forms part of the Product Information File (PIF) and must be available to the competent authorities at the address indicated by the Responsible Person.
In Great Britain, a safety assessment and equivalent technical documentation are also required. Although the structure remains very similar to the European system, the documentation must be valid for the British market and fall under the responsibility of the corresponding Responsible Person.
This means that companies must check whether their CPSR and PIF:
- Reflect the formula actually placed on the market.
- Are up to date.
- Include the necessary toxicological data.
- Consider the intended use of the product.
- Match the labelling.
- Are consistent with the notification submitted.
- Are available to the competent authority in the corresponding jurisdiction.
Having “a CPSR done” is not enough. That document must fit the product, the market and the applicable Responsible Person. The PDF file does not acquire regulatory powers just because it is neatly named in a folder.
Labelling: small changes with major impact
Labelling is one of the most visible elements of regulatory compliance.
In both markets, the product must include essential information such as:
- Name or company name and address of the Responsible Person.
- Nominal content.
- Date of minimum durability or PAO, where applicable.
- Precautions for use.
- Batch number.
- Product function, unless it is obvious.
- List of ingredients.
- Country of origin, where mandatory.
However, after Brexit, important practical differences may arise.
A product intended for the European market must show the address of the Responsible Person established in the EU. By contrast, a product intended for Great Britain must include the information corresponding to the Responsible Person applicable for that market.
When the same product is marketed in both markets, the label must be carefully reviewed to avoid contradictions, incomplete information or invalid addresses.
Attention should also be paid to:
- Translations.
- Cosmetic claims.
- Mandatory warnings.
- Restricted ingredients.
- Fragrance allergens.
- Nanomaterials.
- Country of origin.
- Differences between the EU, Great Britain and Northern Ireland.
A labelling error can lead to commercial blocks, requests from authorities or the need to relabel product that has already been manufactured.
Ingredients and regulatory divergence
Although UK cosmetics regulation is based on a framework very similar to the European one, the United Kingdom’s departure from the EU allows both systems to evolve differently.
This means that, over time, differences may appear in:
- Prohibited substances.
- Restricted substances.
- Authorised preservatives.
- Authorised colourants.
- Authorised UV filters.
- Conditions of use.
- Concentration limits.
- Mandatory warnings.
For this reason, companies marketing products in both markets should not assume that a formula valid in the EU will always be valid in Great Britain, or vice versa.
The regulatory review of ingredients must be carried out for each market and kept up to date with regulatory changes.
Northern Ireland and the role of the Windsor Framework
Northern Ireland deserves a specific review within any post-Brexit strategy.
Although it is part of the United Kingdom, the framework applicable to cosmetic products maintains a special relationship with European rules. This means that products intended for Northern Ireland may require:
- Compliance with the European Regulation.
- A Responsible Person established in the EU or Northern Ireland.
- Notification in the CPNP.
- Labelling in accordance with the requirements applicable in that market.
In addition, when products move between Great Britain and Northern Ireland, additional obligations may arise relating to importation, country of origin and traceability.
For this reason, a regulatory strategy for the “United Kingdom” must clarify from the beginning whether it refers only to Great Britain or also to Northern Ireland.
Common mistakes when marketing cosmetics in the EU and United Kingdom
The most common mistakes include:
- Assuming that a CPNP notification is valid for Great Britain.
- Assuming that an SCPN notification is valid for the European Union.
- Failing to appoint a valid Responsible Person in each market.
- Using a label with an address that is not valid for the target market.
- Failing to distinguish between Great Britain and Northern Ireland.
- Marketing a product with an outdated CPSR or one that is not adapted to the real product.
- Failing to review ingredient restrictions in both regulatory frameworks.
- Failing to update notifications when the formula, labelling or Responsible Person changes.
- Treating the PIF as a static file rather than living documentation.
- Failing to verify claims, warnings and translations before printing.
These errors can generate delays, distribution blocks, relabelling costs or problems during an inspection.
How to Comply with Cosmetic Regulation in the EU and UK
To market a cosmetic product in the European Union and the United Kingdom, it is advisable to follow an organised strategy:
- Define the target markets: EU, Great Britain, Northern Ireland or all of them.
- Identify the applicable Responsible Person in each market.
- Review the formula against current restrictions.
- Prepare or adapt the CPSR and PIF.
- Check that the labelling complies with the requirements of each jurisdiction.
- Review claims, warnings and declared ingredients.
- Complete the notification in CPNP, SCPN or both systems, as applicable.
- Keep the documentation updated after any change.
- Periodically review regulatory developments in both markets.
This approach helps reduce risks and prevents regulatory compliance from becoming an emergency correction just before launch.
How SHAPYPRO can help
At SHAPYPRO, we help cosmetic companies, manufacturers, brands and importers interpret and manage the regulatory requirements applicable in the European Union and the United Kingdom.
Our services may include:
- Regulatory review of formulas.
- Assessment of ingredients and applicable restrictions.
- Preparation and review of the CPSR.
- Preparation and maintenance of the PIF.
- Review of labelling and claims.
- Support with CPNP notification.
- Support with SCPN documentation.
- Consistency review between formula, CPSR, label and notification.
- Advice for products intended for the EU, Great Britain and Northern Ireland.
This approach helps identify differences between markets, avoid unnecessary duplication and keep documentation aligned with the applicable requirements.
Conclusion
After Brexit, cosmetic regulation in the European Union and the United Kingdom still shares a similar technical basis, but the practical obligations are no longer identical.
The Responsible Person, notification, labelling, technical documentation and the management of Northern Ireland must be analysed separately to avoid compliance errors.
A cosmetic product that complies in the EU is not automatically ready for Great Britain, and a UK notification does not replace European compliance.
For companies operating in both markets, the key is to plan from the beginning, review the formula and labelling for each jurisdiction and keep documentation up to date.
In regulated cosmetics, the difference between entering the market safely and accumulating delays often lies in the details: the right Responsible Person, the right portal, the right label and coherent documentation.