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Ensuring that your products’ labelling is compliant with the relevant regulatory requirements is one of the most important steps that must be taken to ensure the products’ overall compliance.
As the most obvious, and easily assessed, aspect of your products, non-compliant labelling can attract negative attention from consumers and authorities and give rise to further problems for your products, with far reaching consequences of both a legal and financial nature.
Timeline to comply with the UK Cosmetic Regulation
The draft UK Cosmetic Regulation foresees a two-year transition period for the labelling compliance of products that are placed on the UK market after 1 January, 2021. This means that for two years after Brexit, products can continue being placed on the UK market with labels that are compliant in the EU. Products which have been placed on the UK market prior to January 1, 2021, and which feature compliant labels under the EU regulation, can continue being sold on the UK market indefinitely.
New labelling requirements of the UK Cosmetic Regulation
The majority of the labelling requirements and mandatory elements under the new UK Cosmetic law are the same as those under the EU law. However:
- One of the new requirements under the UK Regulation is that the country of origin must be stated on the label for all products manufactured outside of the UK, for ex. Made in EU is not compliant.
- Another element which is not new, as such, but indirectly calls for updated labels, is the requirement to include on the label (inner and outer) the UK-based RP’s details. Manufacturers will therefore have two years to start printing and putting into circulation product labels with the name and address of their newly appointed UK RP*.
*Please note that ONLY ONE RP’s details can be included on a given label. It is not possible to print a single label with both your EU and UK RP’s details on it, to be used in both markets. In order to update the label during the transition period, companies that are selling on both markets may choose to label both the UK and the EU-27 RP addresses, highlighting the current RP address. The requirement to add and underline your UK RP to the label is applicable as of 1 January, 2021, however, with a transition period of 2 years for an EU-compliant label that already has a EU RP affixed.