OPSS extends transitional labelling provisions for cosmetics to 2025

On September 5, 2022, the Office for Product Safety and Standards (OPSS) published a new update on the transitional labelling requirements of cosmetic products. The novelty consists in the extension of the validity of the transitional provisions for placing cosmetic products on the market in Great Britain until December 31, 2025. 

The original grace period 

After Brexit, the United Kingdom had to fill the gaps left in its legislation on cosmetic products, as the EU law was no longer applicable. As a result, the UK Cosmetics Regulation, namely the transposition of the EU Cosmetics Regulation with few changes, entered into force. At first, it foresaw a transitional period of two years for manufacturers to comply with the newly amended labelling requirements. Thus, in the beginning, the two-year transitional period was set to expire on December 31, 2022. After this period’s expiry, all products placed on the UK market were to comply with the newly enacted UK Cosmetics Regulation in full or otherwise be withdrawn from the market (CTPA, 2022).  

 The extension  

Through its latest decision on the UK Cosmetics Regulation, on September 5, 2022, the OPSS has changed its stance on the duration of the grace period, extending it to a total period of 5 years. Moreover, in order to give a better understanding of the newly implemented amendments, the UK updated its Statutory Guidance on the Cosmetic Products Enforcement Regulations 2013. 

Consequently, until December 31, 2025, beauty brands may still be compliant with the labelling requirements applicable to cosmetic products by fulfilling the conditions of Article 19(1)(a) of the EU Cosmetic Products Regulation. The paragraph requires cosmetic products to mention, among others: 

  • The name and address of the Responsible Person;  
  • The country of origin of the cosmetic product, unless it has been manufactured in the EU. 

Hence, until December 31, 2025, cosmetic brands can sell their cosmetic products in Great Britain with the same labels the EU market 

Nevertheless, there is no transition period for artwork if the previous EU RP was based in the UK.  

However, it must be highlighted that this decision does not affect the other requirements, including those for SCPN registration and appointment of a UK-based Responsible Person. Any Non-UK brand owner must designate a UK RP as of January 1, 2021 if they wish to make their cosmetics available on the UK market.

Cosmetic manufacturers are therefore encouraged to start reassessing their compliance with the future UK Cosmetic Products Regulations requirements. You can contact us to receive further information.

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Davide Baldessari 

RA Department  



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