A separate UK compliance process now needs to be undertaken to sell cosmetics in Great Britain. Brands that only notify under EU CPNP 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. This guide will explain UK Cosmetics Regulatory Requirements & Registration Process and how companies can enter the market.
Regulatory Authority for Cosmetics in the UK
The UK cosmetics regulator is the Office for Product Safety and Standards (OPSS) 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 repair.
- 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.
- Deodorants.
- Toothpaste.
In the UK, products intended to be eaten, inhaled, injected, or inserted into the body are not considered cosmetics.
Compliance Requirements for Cosmetics in UK
Cosmetic products sold in Great Britain must meet multiple compliance requirements before entering the market.
1. 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.
2. 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.
3. 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.
Also Read: Medical Device Regulations and Registration In UK (MHRA)
Cosmetic Registration Process in UK
The cosmetic registration UK 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.
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 photograph.
- 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.
Also Read: MHRA Pharmaceutical Regulations and Registration in the UK
Cosmetics Labeling Requirements in 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 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.
Ingredient Regulations and Safety Requirements in UK
Ingredient and formulation reviews are an important part of UK cosmetic compliance requirements.
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.
UK Cosmetic GMP Requirements
Manufacturers are expected to adhere to Good Manufacturing Practice (GMP) standards to maintain product quality, traceability, and manufacturing consistency.
Manufacturing documentation must also be available for inspection as part of the compliance process.
Import Requirements for Cosmetics in 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.
Timeline for Cosmetic Registration in UK
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 UK
Major compliance expenses are:
- Services for the responsible person in the UK.
- Safety assessments.
- Testing.
- Relabeling.
- Ongoing notification updates.
Product Safety & PMS for Cosmetics in UK
After a cosmetic product is placed on the Great Britain market, manufacturers and the UK Responsible Person (UK RP) must continue to ensure compliance with UK cosmetics regulations through post-market surveillance (PMS). This includes monitoring product safety, maintaining technical documentation, reporting Serious Undesirable Effects (SUEs) where required, and cooperating with UK authorities during inspections or compliance investigations.
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.
Latest Changes to UK Cosmetics Regulations
Great Britain has implemented a number of regulatory changes for cosmetic products entering the GB market since Brexit.
Key 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.
