Do I need a UK Responsible Person if I already have an EU one?

Yes. Since Brexit, an EU Responsible Person cannot fulfill the UK RP role for products sold in Great Britain. You need a UK-based Responsible Person with a UK address. Northern Ireland is an exception — EU RP can still serve NI under the Windsor Framework.

Can I use my EU CPSR for the UK market?

Generally yes. The UK accepts safety assessments that follow the EU Regulation 1223/2009 Annex I format. Your existing CPSR should be valid for UK compliance, provided it's available in English and the assessor has recognized qualifications.

Is CPNP notification valid for the UK?

No. CPNP notifications only cover EU Member States. For Great Britain, you must submit a separate notification through the SCPN (Submit Cosmetic Product Notifications) portal. Northern Ireland may still require CPNP notification under the Windsor Framework.

What happens if I sell in the UK without a UK Responsible Person?

Selling cosmetics in Great Britain without a UK Responsible Person is illegal. OPSS can issue enforcement notices, require product withdrawal, and pursue prosecution. The Responsible Person requirement is strictly enforced post-Brexit.

Are UK ingredient restrictions the same as EU?

Currently they are largely aligned, as the UK adopted EU rules at Brexit. However, the UK can now diverge and is considering independent positions on certain ingredients. Always check current UK Schedules rather than assuming alignment with EU Annexes.

Do I need to relabel products for the UK market?

Likely yes. Products previously sold with only an EU Responsible Person address need to be updated to show a UK address. You may be able to add a UK address sticker or use dual-address labels for both markets.

How long does UK market entry take?

If you have existing EU-compliant products, UK market entry can take 4-8 weeks to arrange a UK RP, update labels, and submit SCPN notifications. New products requiring CPSR, testing, etc. take the same timeline as EU market entry (4-8 months).

Can I sell to both UK and EU with one product label?

Yes, if you include both UK and EU Responsible Person addresses on the label. This dual-address approach allows a single SKU to serve both markets, though you still need separate notifications in SCPN and CPNP.

UK Cosmetic Regulations Post-Brexit: Complete Compliance Guide

UK Cosmetic Regulations After Brexit

Since the UK left the European Union on January 31, 2020, cosmetic regulations in Great Britain have diverged from EU rules. According to official UK government guidance, cosmetics sold in the UK must now comply with UK-specific regulations rather than EU law.

Great Britain vs. Northern Ireland

This guide covers Great Britain (England, Scotland, Wales). Northern Ireland follows different rules under the Windsor Framework and generally continues to follow EU cosmetic regulations. If you're selling in Northern Ireland, see our guide on the NI Protocol.

The primary legislation governing cosmetics in Great Britain is the Cosmetic Products Enforcement Regulations 2013, as amended post-Brexit. This retained EU Regulation 1223/2009 in UK law but with important modifications.

Key Changes Since Brexit

Brexit introduced several significant changes for cosmetic compliance in the UK:

UK Cosmetic Regulations: Pre-Brexit vs. Post-Brexit
Requirement	Pre-Brexit (EU Member)	Post-Brexit (GB)
Product Notification	CPNP (EU portal)	SCPN (UK portal)
Responsible Person	EU-based RP sufficient	UK-based RP required
Safety Report	CPSR required	CPSR still required
Ingredient Restrictions	EU Annexes applied	UK Annexes (diverging)
Regulatory Authority	EU Commission	OPSS / Secretary of State
Market Access	Single notification for EU+UK	Separate UK notification required

The Practical Impact

For most brands, Brexit means duplicating compliance efforts. You now need a UK Responsible Person AND an EU Responsible Person, plus separate product notifications in both SCPN (UK) and CPNP (EU).

UK Responsible Person Requirement

The most significant post-Brexit change is the requirement for a UK-based Responsible Person. According to OPSS Responsible Person guidance:

Who Must Have a UK Responsible Person?

UK Responsible Person Requirements by Business Type
Business Type	UK RP Required?	Notes
UK manufacturer selling in UK	Yes (manufacturer is RP)	Automatic designation
EU company selling in UK	Yes	Must appoint UK-based RP
US company selling in UK	Yes	Must appoint UK-based RP
UK importer from non-UK	Yes (importer becomes RP)	Unless manufacturer appoints UK RP
UK distributor only	No (unless modifying)	RP remains with manufacturer/importer

UK Responsible Person Duties

The UK Responsible Person has the following obligations under UK regulations:

UK Responsible Person Obligations

Ensure the cosmetic product has a valid safety assessment (CPSR)
Submit product notification to SCPN before placing on GB market
Maintain the Product Information File for 10 years after last batch
Ensure labeling complies with UK requirements
Report serious undesirable effects to OPSS
Provide Product Information File to enforcement authorities on request
Ensure manufacturing complies with Good Manufacturing Practice
Cooperate with authorities on any corrective actions or recalls

SCPN: UK Product Notification

The Submit Cosmetic Product Notification (SCPN) portal replaced CPNP access for Great Britain. According to the SCPN user guide:

How to Submit an SCPN Notification

Create an Account

Gather Required Information

Prepare product name, category, responsible person details, formulation (frame formulation or exact), and label images.

Enter Product Details

Submit the product category, physical form, and intended use information through the online form.

Upload Formulation Data

Provide either frame formulation (percentage ranges) or exact formulation. Include all INCI names.

Add Label Information

Upload images of product labels showing all required information including warnings and ingredients.

Submit Notification

Review all information and submit. Notification must be complete before placing product on GB market.

Maintain and Update

Update the notification if formulation changes, and notify OPSS of any serious undesirable effects.

UK Product Safety Assessment

The UK retained the requirement for a Cosmetic Product Safety Report (CPSR) equivalent. Per OPSS guidance:

UK Safety Assessment Requirements

Safety assessment must follow format equivalent to EU Regulation 1223/2009 Annex I
Assessment must be signed by a qualified safety assessor
Assessor qualifications same as EU (pharmacy, toxicology, medicine, or similar)
UK or EU qualified assessors both accepted
Assessment must be available in English
Must be kept as part of Product Information File

Existing CPSRs Valid

If you already have a valid CPSR prepared for the EU market, it will generally be accepted for UK compliance, provided it meets the UK requirements and is available in English. No need to prepare a separate UK-specific safety report.

UK Ingredient Restrictions

Initially, the UK adopted all EU ingredient restrictions. However, regulatory divergence means the UK can now set its own rules. According to recent UK amendments:

UK vs. EU Ingredient Regulation Status (2026)
Category	UK Status	Divergence from EU
Prohibited Substances (Annex II)	UK Schedule 2	Minor divergence beginning
Restricted Substances (Annex III)	UK Schedule 3	Some differences emerging
Permitted Colorants (Annex IV)	UK Schedule 4	Aligned currently
Permitted Preservatives (Annex V)	UK Schedule 5	Aligned currently
Permitted UV Filters (Annex VI)	UK Schedule 6	Aligned currently

* UK may diverge further on specific ingredients based on UK-specific risk assessments

* Always check current UK schedules before formulation finalization

UK Labeling Requirements

UK labeling requirements are largely similar to EU but with key differences. Per OPSS labeling guidance:

UK Cosmetic Labeling Requirements

Product name and function
Ingredients list (INCI names, descending order)
Nominal content (weight or volume)
Date of minimum durability or PAO symbol
Batch number or reference for identification
UK Responsible Person name and address
Country of origin (if imported from outside UK)
Warnings and conditions of use as required
All mandatory information in English

Critical Labeling Change

Post-Brexit, labels must show a UK address for the Responsible Person. An EU address alone is no longer sufficient for products sold in Great Britain. This may require relabeling products previously sold with only an EU RP address.

Enforcement and Penalties

The Office for Product Safety and Standards (OPSS) is the primary enforcement authority for cosmetics in Great Britain. According to OPSS enforcement policy:

UK Cosmetic Enforcement Measures
Measure	When Used	Consequence
Compliance Notice	Minor non-compliance	Must remedy within specified time
Withdrawal Notice	Unsafe product identified	Remove from market
Recall Notice	Serious safety concern	Retrieve from consumers
Prohibition Notice	Persistent non-compliance	Cannot place products on market
Prosecution	Serious breaches	Fines, potential imprisonment

Active Enforcement

OPSS conducts regular market surveillance and has increased enforcement activity post-Brexit. Non-compliant products are regularly identified and removed from market, with enforcement notices published publicly.

Northern Ireland: Special Rules

Windsor Framework

Northern Ireland operates under the Windsor Framework (previously NI Protocol). Cosmetics sold in Northern Ireland generally follow EU rules, meaning: - CPNP notification still required (not SCPN) - EU Responsible Person can serve NI market - EU ingredient rules apply - Products must comply with EU Regulation 1223/2009

Key Takeaways

Post-Brexit, Great Britain requires a UK-based Responsible Person — EU RP is not sufficient

Product notifications must be submitted to SCPN (UK portal), not CPNP (EU portal)

Existing CPSRs from EU compliance are generally acceptable for UK if in English

Labels must show a UK address for the Responsible Person

Northern Ireland follows EU rules under the Windsor Framework

Monitor regulatory divergence — UK may implement different ingredient rules than EU

Dual-market brands need separate RP arrangements and notifications for UK and EU

Check Your UK Compliance Status

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