A separate UK compliance process now needs to be undertaken to sell cosmetics in Great Britain. Brands that only notify under EU CPNPs may experience a delay in launch as products must meet the UK requirements before they can be launched in England, Scotland, and Wales.
The most difficult problems faced by regulatory and commercial teams are a lack of technical documentation, non-compliant labels, late notifications, and importer responsibilities. These result in shipment holds, relabeling expenses, retailer onboarding problems, and marketplace delistings throughout the UK.
Cosmetics Regulatory Authority in the UK
The Office for Product Safety and Standards (OPSS) regulate cosmetics in Great Britain. Cosmetic products which are marketed in GB must be notified on the UK Submit Cosmetic Product Notification (SCPN) portal prior to sale.
The responsibility for enforcement lies with Trading Standards authorities who can take action if products are unsafe, claims are not substantiated, labels are not compliant, or compliance papers are not available.
Cosmetics Classification in UK
In the UK, a cosmetic product must satisfy three criteria: product function, field of application, and product composition.
Cosmetic products are mainly intended to:
- Clean.
- Perfume.
- Protect.
- Maintain good repairs.
- Change appearance.
- Correct body odours.
Cosmetic products can be used on:
- The epidermis.
- The hair system.
- Nails.
- Lips.
- External genital organs.
- Teeth.
- Mucous membranes of the oral cavity.
This includes products such as:
- Skincare products.
- Makeup products.
- Shampoos.
- Perfumes.
- Deodorant.
- Toothpaste.
In the UK, products that are meant to be eaten, breathed, injected, or inserted into the body are not considered cosmetics.
Products that claim to be medicinal, therapeutic or antimicrobial are often subject to borderline classification problems. Products that claim to treat acne, control infections, repair skin, or grow hair may fall outside the cosmetics category and are subject to other regulatory requirements.
Compliance Requirements for Cosmetics in UK
Cosmetic products sold in Great Britain must meet multiple compliance requirements before entering the market.
Responsible Person (UK RP)
All cosmetic products sold in Great Britain should be assigned to a Responsible Person (UK RP) in the UK. Prior to the sale of products in England, Scotland and Wales, the UK RP is responsible for ensuring product compliance.
The UK RP may be a manufacturer, importer or distributor, or third-party regulatory partner based in the UK. They are responsible for the Product Information File (PIF), SCPN notifications, post-market compliance, and for answering requests from the UK authorities.
Many cosmetic companies experience delays or failures in getting their products on the market due to incorrect information about UK RP on the cosmetic label, lack of transfer of technical documentation or due to the fact that the distributor does not have regulatory resources of its own.
Product Information File (PIF)
All cosmetics sold in Great Britain are required to contain:
- A Product Information File (PIF).
- Documentation for manufacture, subject to inspection.
Some of the most frequent non-compliances are:
- Incomplete toxicology data.
- Missing supplier documentation.
- Unsupported product claims.
- Outdated technical files.
Cosmetic Product Safety Report (CPSR)
All cosmetics sold in Great Britain are required to contain:
- A Cosmetic Product Safety Report (CPSR).
- Providing safety and testing information.
Most launch delays occur because of incomplete supplier information, unsupported claims, or missing safety documentation.
Cosmetic Registration Process in the UK
The UK cosmetic product notification process involves multiple compliance and documentation steps before products can be placed on the Great Britain market.
Step 1: Appoint a UK Responsible Person
A Responsible Person (UK RP) in the UK is required to submit the SCPN notification. Cosmetic products cannot be legally placed on the Great Britain market without a UK RP.
Step 2: Create Technical Documentation
Prior to notification, brands need to complete:
- Product Information File (PIF).
- Cosmetic Product Safety Report (CPSR).
- Review and evaluation of ingredients and formulation.
- Label compliance checks.
Most launch delays occur at this stage because of incomplete supplier information, unsupported claims, or missing safety documentation.
Step 3: Review Product Labels
All products are required to have the following on their labels:
- Details of the UK Responsible Person.
- INCI ingredient declarations.
- Warnings and precaution statements.
- Mandatory information in English for GB sales.
Incorrect or outdated artwork is one of the most common reasons for relabeling and retailer onboarding delays.
Step 4: Submit SCPN Notification
The notification is submitted through the UK Submit Cosmetic Product Notification (SCPN) portal by the UK Responsible Person before the product is placed on the GB market.
The submission includes:
- Product category and product name.
- Details of the UK Responsible Person.
- Product label image.
- Product packaging photographs.
- Location of the Product Information File (PIF).
- Urgent contact details.
- Summary of ingredients.
- Nanomaterial information, where applicable.
- CMR substance information, where applicable.
The SCPN is a notification system, not a product approval process.
Step 5: Ensure Continuous Compliance
SCPN notifications must be updated when there are:
- Formula changes.
- Label updates.
- Changes to the UK Responsible Person.
- Packaging changes affecting compliance information.
For global cosmetics brands, managing SCPN updates across large SKU portfolios and parallel UK-EU compliance systems remains one of the biggest operational challenges.
UK Cosmetics Regulatory Framework Post-Brexit
Great Britain has been maintaining a Cosmetics Compliance framework independent of the EU since Brexit. Cosmetic products sold in England, Scotland, and Wales have to meet UK requirements such as notification via the UK Submit Cosmetic Product Notification (SCPN) portal before products are available on the market.
The EU Cosmetics Regulation also governs cosmetics sold in Northern Ireland and the EU, meaning that brands selling in both markets may require different compliance processes in the UK and EU.
The most significant issues for global cosmetic companies following Brexit are parallel compliance management of the UK and EU, updating labels, new importer liability and having a coherent technical documentation in different markets.
UK Responsible Person Requirements for Cosmetics
All cosmetic products sold in Great Britain should be assigned to a Responsible Person (UK RP) in the UK. Prior to the sale of products in England, Scotland and Wales, the UK RP is responsible for ensuring product compliance.
The UK RP may be a manufacturer, importer or distributor, or a third party regulatory partner based in the UK. They are responsible for the Product Information File (PIF), SCPN notifications, post-market compliance and for answering requests from the UK authorities.
Many cosmetic companies experience delays or failures in getting their products on the market due to incorrect information about UK RP on the cosmetic label, lack of transfer of technical documentation or due to the fact that the distributor does not have regulatory resources of its own.
Cosmetic Labeling Requirements in the UK
Cosmetic products sold in Great Britain have to contain:
- Name and address of Responsible Person in the UK.
- List of ingredients in the INCI format.
- Batch No or Product Reference.
- Nominal content.
- Where appropriate, warnings and precautions.
- Minimum durability date / Period After Opening (PAO).
- Unless otherwise clearly indicated by the product’s presentation, the product is not intended to function as a product.
- All information that is required must be in English.
A typical post-Brexit compliance challenge has been the use of EU-only artwork for GB products. Shipment delays, product claims and incorrect allergen declarations often result in retailer rejection and relabeling costs, and are common reasons for missing UK Responsible Person details.
UK Cosmetics Safety and Technical Documentation Requirements
All cosmetics sold in Great Britain are required to contain:
- A Product Information File (PIF).
- A Cosmetic Product Safety Report (CPSR).
- Providing safety and testing information.
- Documentation for manufacture, subject to inspection.
Some of the most frequent non-compliances are:
- Incomplete toxicology data.
- Missing supplier documentation.
- Unsupported product claims.
- Outdated technical files.
Manufacturers are also expected to adhere to Good Manufacturing Practice (GMP) standards to maintain the quality of the product and traceability.
Importing Cosmetics into Great Britain (UK)
Importers of cosmetics into Great Britain (UK) have been left with some compliance obligations that were previously handled by the EU supply chain after Brexit.
Some of the most frequent causes of shipment delays are:
- Responsible Person details are missing.
- Incomplete SCPN notifications.
- Inconsistent labels.
- Unavailable technical documentation.
Global brands are facing a significant operational challenge when they have to manage two different inventories, packaging, and compliance workflows in the UK and the EU.
Post-Market Surveillance and Enforcement in the UK
Cosmetics already on the market can be investigated by UK authorities at any time, and technical documentation can be requested.
Some enforcement action triggers are:
- Missing SCPN notifications.
- Unsupported product claims.
- Non-compliant labels.
- Incomplete technical files.
- Unreported serious undesirable effects.
Such problems may result in product recalls, retailer disassociations, and government interventions.
UK Cosmetics Compliance Timelines
The UK cosmetics compliance dates are primarily based on:
- Safety assessment readiness.
- Supplier documentation.
- Label compliance.
- SCPN submission accuracy.
Typically, delays occur during:
- Artwork corrections.
- CPSR preparation.
- Portfolio-wide notification projects.
Cosmetic Registration Fees in the UK
Major compliance expenses are:
- Services for the person responsible in the UK.
- Safety assessments.
- Testing.
- Relabeling.
- Ongoing notification updates.
Latest Changes to the UK Cosmetics Regulations
Great Britain has implemented a number of regulatory changes for cosmetic products entering the GB market since Brexit.
UK Cosmetic regulatory changes include:
- Cosmetic products sold in Great Britain must now have a Responsible Person (UK RP) based in the UK.
- Cosmetic products are not notified via the EU Cosmetic Product Notification (CPNP) system but rather via the UK Submit Cosmetic Product Notification (SCPN) system.
- Importers who import cosmetic products from the EU into Great Britain are now deemed to be the importer and not the distributor and can be the default UK Responsible Person.
- The Product Information File (PIF) should be kept in English and be provided to UK authorities when requested.
- Cosmetic products with serious Undesirable Effects (SUEs) must be reported to UK authorities.
- Some novel nanomaterials in cosmetic products could need to be notified 6 months prior to being marketed in the GB.
- The EU cosmetics rules still apply to products sold in Northern Ireland, and the UK cosmetics framework applies to products sold in Great Britain.
The changes have added to the compliance burden for brands operating parallel cosmetic businesses in the UK and EU.
Conclusion
For brands selling in Great Britain, there are now UK-specific requirements for SCPN notification, UK Responsible Person appointment, labelling, and technical documentation to be addressed prior to products coming to market.
These activities are most often the cause of launch delays because they are not done in a coordinated compliance process. Shipment holds, retailer onboarding challenges, and relabeling expenses persist for global cosmetics brands due to missing UK RP details, incomplete documentation, labeling gaps, and delayed notifications.
For a smoother entry into the UK Cosmetics market, get in touch with the experts at Artixio. With years of experience in the overseas regulatory market, we can help you with cosmetic registration in the UK. From labeling to getting the products notified, our team can guide you throughout the process. For more information, reach out to us at info@artixio.com.
