🇬🇧UK Compliance

UK vs EU Cosmetic Regulations: Complete Comparison Guide

UK vs EU cosmetic regulations compared. Key divergences since Brexit, SCPN vs CPNP, UK RP vs EU RP, and dual-market compliance requirements.

Verified January 17, 2026

Guide Information

Published by: Global Cosmetic Regs Editorial Team

Last updated: January 17, 2026

Verified against: GB Cosmetic Guidance, UK Retained Cosmetics Reg

Sources: 6 official documents

View our methodology →

UK vs EU Cosmetic Regulations: Complete Comparison Guide

Since Brexit, UK and EU cosmetic regulations have begun diverging. While both share the same foundation — Regulation (EC) 1223/2009 — the UK now amends its retained version independently through Statutory Instruments, while the EU updates through Commission Regulations. According to UK government guidance, brands selling in both markets must comply with both sets of requirements.

Dual-Market Compliance Required

EU compliance does NOT equal UK compliance (and vice versa). Products sold in both markets require separate Responsible Persons, separate notifications (CPNP and SCPN), and verification against both annex systems. Assuming equivalence risks non-compliance.
UK and EU share Regulation 1223/2009 as baseline but now diverge
UK requires UK RP + SCPN notification; EU requires EU RP + CPNP notification
Fragrance allergens: UK requires 26 declarations, EU now requires 80+
Ingredient restriction timelines and limits may differ between jurisdictions
Northern Ireland follows EU rules (Windsor Framework)
UK RP labeling transition ends December 31, 2027
CPSR format is the same but must verify compliance for each market

Regulatory Framework Comparison

UK vs EU Cosmetic Regulatory Framework
AspectUK (Great Britain)EU (27 Member States)
Base RegulationRetained Regulation 1223/2009Regulation (EC) 1223/2009
Amendment MechanismUK Statutory InstrumentsEU Commission Regulations
Enforcement AuthorityOPSS, Trading StandardsNational competent authorities
Notification PortalSCPNCPNP
Responsible PersonUK-based onlyEU/EEA-based only
Ingredient UpdatesIndependent UK processEU Commission decisions
Scientific CommitteeUK expert committee (ad hoc)SCCS (ongoing)

Source: UK and EU Regulations

Responsible Person Requirements

UK RP vs EU RP Comparison
RequirementUK Responsible PersonEU Responsible Person
LocationMust be established in Great BritainMust be established in EU or EEA
For Northern IrelandEU RP requiredEU RP required
Legal ObligationsSame structure (safety, PIF, notification)Same structure
LabelingUK RP address on labelEU RP address on label
Same Entity Possible?Only if established in bothOnly if established in both
Third-Party ServicesAvailableAvailable

Source: UK and EU Regulations

Northern Ireland: Special Case

Under the Windsor Framework, Northern Ireland continues to follow EU cosmetic regulations. Products sold in NI require an EU Responsible Person and CPNP notification, not UK RP and SCPN. Products sold throughout the UK (GB + NI) need both.

Labeling Transition

UK RP Labeling Transitional Period
SituationRequirementDeadline
Products placed on GB market before 2021EU RP address acceptableUntil stock exhausted
New products or relabeled productsUK RP address requiredNow
All products on GB marketUK RP address mandatoryDecember 31, 2027

Source: UK Regulations

Notification Systems: SCPN vs CPNP

SCPN vs CPNP Notification Comparison
FeatureUK SCPNEU CPNP
Full NameSubmit Cosmetic Product NotificationsCosmetic Products Notification Portal
URLsubmit.cosmetic-product-notifications.service.gov.ukec.europa.eu/growth/tools-databases/cosing/cpnp
AccessFree, online registrationFree, online registration
When to NotifyBefore placing on GB marketBefore placing on EU market
Information RequiredProduct details, frame formulation, CPSR summary, labelsSame structure
CMR DeclarationRequiredRequired
Nanomaterial NotificationRequired (6 months advance)Required (6 months advance)
Update RequirementWithin 1 month of changesWithout delay when changes occur
LanguageEnglishMultiple EU languages supported

Source: UK SCPN Guidance, EU CPNP Guidance

Products Requiring Dual Notification

When You Need Both SCPN and CPNP

  • Selling in Great Britain AND any EU member state
  • Selling in Great Britain AND Northern Ireland
  • Exporting to both UK and EU markets
  • Online sales accessible to both UK and EU consumers
  • Wholesale to distributors who sell in both markets

Ingredient Restrictions: Key Divergences

Since Brexit, several ingredient restrictions have diverged between UK and EU:

Notable UK vs EU Ingredient Divergences (2025)
IngredientUK RestrictionEU RestrictionDivergence
Fragrance allergens (declaration)26 allergens80+ allergensMajor divergence
Vitamin A (face products)UK has NOT adopted0.3% RE (Nov 2025)Major divergence — UK pending
Homosalate7.34% (July 2025)7.34% (similar)Aligned but separate process
HICC (Lyral)ProhibitedProhibitedAligned
LilialProhibited (March 2022)Prohibited (March 2022)Aligned
Salicylic acid (rinse-off)2%2%Currently aligned
Titanium dioxide (oral)Under reviewProhibited (food, being reviewed for cosmetics)May diverge

* This table shows examples — always verify current status in both jurisdictions

Source: UK and EU Regulations

Fragrance Allergen Divergence

The most significant current divergence is fragrance allergen declaration:

Fragrance Allergen Requirements Comparison
AspectUKEU
Number of declarable allergens2680+
Leave-on threshold0.001% (10 ppm)0.001% (10 ppm)
Rinse-off threshold0.01% (100 ppm)0.01% (100 ppm)
New allergens addedNone54+ additional allergens
Compliance statusNo change — 26 allergensIn force; 80+ required on products placed on the market

Source: UK Annex III, EU Regulation 2023/1545

Dual-Market Labeling Impact

Products sold in both UK and EU now need different ingredient lists. EU labels must declare 80+ fragrance allergens; UK labels require only 26. Brands can either: 1. Use EU-compliant labels (more allergens) for both markets 2. Create market-specific labels The first approach is simpler but adds label complexity; the second adds operational complexity.

Safety Assessment Comparison

CPSR Requirements: UK vs EU
AspectUKEU
Required?Yes, before placing on marketYes, before placing on market
FormatPart A (safety data) + Part B (assessment)Same format
Assessor QualificationSpecified diploma (toxicology, pharmacy, etc.)Same requirements
Ingredient DataMust use UK AnnexesMust use EU Annexes
Margin of Safety≥100 (same methodology)≥100 (same methodology)
One CPSR for Both?Possible if complies with both marketsPossible if complies with both markets
Retention10 years after last batch10 years after last batch

Source: UK and EU Regulations

Single CPSR for Both Markets

A well-prepared CPSR can serve both UK and EU markets if it: - Verifies compliance against BOTH UK and EU Annexes - Documents any differences in restrictions - Is accessible to both UK RP and EU RP - Is updated when either jurisdiction changes requirements

Labeling Requirements Comparison

Labeling Requirements: UK vs EU
ElementUK RequirementEU RequirementDifference
RP AddressUK RP (GB address)EU RP (EU/EEA address)Different addresses required
LanguageEnglish (mandatory for GB)Official language(s) of sale countryUK = English only; EU = varies
Ingredients (INCI)Same standardSame standardAligned
PAO/BBESame rulesSame rulesAligned
Batch CodeRequiredRequiredAligned
WarningsUK Annex III warningsEU Annex III warningsMay differ
Fragrance Allergens26 required80+ requiredMajor divergence

Source: UK and EU Article 19

Practical Labeling Solutions

Dual-Market Labeling Options

  • Include both UK RP and EU RP addresses on label (one product SKU)
  • Use most restrictive ingredient list (EU 80+ allergens covers UK 26)
  • Warnings: include all applicable to both markets
  • Create separate UK and EU SKUs with market-specific labels
  • Use peel-back or booklet labels if space is limited
  • Ensure EU labels declare the 80+ allergen list — required on products placed on the market

Testing and Safety Requirements

Testing Requirements: UK vs EU
Test TypeUKEUNotes
Animal TestingBanned for cosmetics/ingredientsBanned for cosmetics/ingredientsAligned
Safety AssessmentRequired (CPSR)Required (CPSR)Aligned format
Stability TestingRequired for CPSRRequired for CPSRAligned
MicrobiologicalRequired where applicableRequired where applicableAligned
Challenge TestingRequired for preserved productsRequired for preserved productsAligned
SPF TestingISO 24444 (in vivo)ISO 24444 (in vivo)Aligned
Nanomaterial SafetyRequired, 6-month advance notificationRequired, 6-month advance notificationAligned

Source: UK and EU Regulations

Enforcement and Penalties Comparison

Enforcement Comparison: UK vs EU
AspectUKEU
Lead AuthorityOPSS + Trading StandardsNational competent authorities
Market SurveillanceRisk-based inspectionsSimilar approach
PIF Request Deadline96 hoursNot specified (but 'promptly')
Maximum FinesUnlimited (serious offenses)Varies by member state
ImprisonmentUp to 3 months (serious offenses)Varies by member state
Product RecallCan be mandatedCan be mandated
Cross-Border CooperationNot automatic with EURAPEX system

Source: UK and EU Regulations

Northern Ireland: The Special Case

Northern Ireland Follows EU Rules

Under the Windsor Framework, Northern Ireland operates under EU cosmetic regulations, not UK rules. This means: - EU Responsible Person required (not UK RP) - CPNP notification required (not SCPN) - EU Annexes apply (not UK Annexes) - EU fragrance allergen rules apply (80+ allergens)
Requirements by UK Nation
NationResponsible PersonNotificationRegulations
EnglandUK RPSCPNUK
ScotlandUK RPSCPNUK
WalesUK RPSCPNUK
Northern IrelandEU RPCPNPEU

Source: UK Government

Timeline of Key Divergences

UK-EU Cosmetic Regulatory Divergence Timeline
DateEventImpact
January 1, 2021Brexit transition endsUK begins independent regulation
January 1, 2021UK RP requirement beginsEU RP no longer valid for GB
January 1, 2021SCPN operationalSeparate notification required for GB
March 2022Lilial banned (UK and EU)Aligned restriction
2023-2024Various SI updatesUK Annexes begin diverging
July 31, 2026EU 80+ allergen requirement took effectUK stays at 26 allergens — divergence begins
December 31, 2027UK RP labeling transition endsUK RP address mandatory on all GB products

Source: UK and EU Regulations

Practical Compliance Checklist

Dual UK-EU Market Compliance Process

1
Establish Responsible Persons

Appoint UK RP for GB market and EU RP for EU market. Can be same entity only if established in both jurisdictions. Third-party services available for both.

2
Verify Ingredient Compliance

Check formulation against BOTH UK Annexes and EU Annexes. Note any differences in concentration limits or restrictions. The more restrictive limit governs if using one formulation.

3
Prepare CPSR

CPSR can serve both markets if it verifies compliance with both. Document any UK-EU differences. Ensure assessor is qualified under both systems (usually the same requirements).

4
Submit Notifications

Notify SCPN for GB market and CPNP for EU market. Information required is similar but systems are separate. UK RP submits to SCPN; EU RP submits to CPNP.

5
Create Compliant Labels

Include both UK RP and EU RP addresses OR create separate market SKUs. Use most restrictive ingredient list (EU allergens cover UK). Add all applicable warnings from both markets.

6
Monitor Both Markets

Track UK Statutory Instruments and EU Commission Regulations. Update formulations, labels, and notifications when either changes. Confirm EU labels already declare the 80+ allergen list, and plan sell-through of pre-31 July 2026 stock before 31 July 2028.

Yes, but you need to comply with both sets of regulations. This requires: a UK Responsible Person AND an EU Responsible Person, SCPN notification AND CPNP notification, compliance with both UK and EU ingredient restrictions, and labeling that meets both requirements (often achieved by including both RP addresses and using the more restrictive ingredient list).

They share the same foundation (Regulation 1223/2009) but have begun diverging since Brexit. Key differences include: fragrance allergen requirements (the UK retains the original 26; the EU now requires 80+), timing of some ingredient restrictions, and separate notification/RP systems. Many requirements still align, but verification against both is essential.

Northern Ireland follows EU cosmetic regulations under the Windsor Framework. Products sold in NI require an EU Responsible Person and CPNP notification, not UK RP and SCPN. The EU's expanded fragrance allergen requirements (80+ allergens) already apply in Northern Ireland.

Yes, if the CPSR is prepared to verify compliance with BOTH UK and EU Annexes. The assessor should document any differences between jurisdictions and confirm the formulation complies with the more restrictive requirements. Both the UK RP and EU RP should hold copies.

Main differences: (1) RP address must be UK-based for GB, EU-based for EU; (2) Language must be English for GB, official language(s) for EU country of sale; (3) Fragrance allergens: the original 26 for the UK, 80+ for the EU now in force. You can include both RP addresses on one label or create market-specific SKUs.

The transitional provision allowing EU RP addresses on GB product labels ends December 31, 2027. After this date, all products on the GB market must display a UK-based Responsible Person address. Plan relabeling activities well in advance of this deadline.

The UK requires declaration of the original 26 fragrance allergens when above thresholds (0.001% leave-on, 0.01% rinse-off). The EU now requires declaration of 80+ allergens on products placed on its market, following the 31 July 2026 cutoff. For dual-market products, using the EU list (80+) satisfies both requirements, but adds label complexity for UK-only products.

Yes, both UK and EU ban animal testing for cosmetic products and their ingredients. Products animal-tested elsewhere cannot be sold in either market. This alignment has remained consistent since Brexit and is not expected to diverge.

Check Your Dual-Market Compliance

Verify your products meet both UK and EU cosmetic requirements.

Start Compliance Check
Sources & References
  1. Office for Product Safety and Standards. "Regulation 2009/1223 and the Cosmetic Products Enforcement Regulations 2013: Great Britain." (2023-05). gov.uk. Accessed 2026-01-16.
  2. UK Government. "Regulation (EC) No 1223/2009 (UK Retained Law)." (2009-11). legislation.gov.uk. Accessed 2026-01-12.
  3. Office for Product Safety and Standards. "Submit a cosmetic product notification - Guidance." (2020-12). gov.uk. Accessed 2026-01-12.

January 17, 2026

Comprehensive UK vs EU comparison with divergence timeline and practical guidance