UK Responsible Person for Cosmetics

UK-based RP and RP by default

• No grace period is foreseen for cosmetic products that are already in circulation on the UK market at the moment in which Brexit comes into full effect
• The name and address of the UK RP must be on the product label (both primary and secondary)
• The UK distributor will become importer and take the role of UK RP if not designated beforehand;
• The obligations of the UK Responsible Person are exactly the same as those entrenched in the EU Cosmetic Regulation as transposed into the UKCPR Article 4.

The UK Notification Portal

• New products placed on the market as of 1 January 2021 must be notified on SCPN prior to being placed on the market. The information that has to be submitted as part of the notification is as per Article 13 of the UK Cosmetics Regulation;
• Products available on the UK market before 1 January 2021 and already notified via the EU Cosmetic Products Notification Portal (CPNP) must be notified within 90 days from 1 January 2021;
• Products intended to be placed on the Northern Irish market must be notified on the EU Cosmetic Products Notification Portal (CPNP), as NI follows EU rules;
• The UK’s notification portal requires the following information:
  1. Products’ name and category;
  2. The Responsible Person name and address and contact details of a natural person;
  3. The products’ frame formulation

The name and address of the UK RP must be on the product label (both primary and secondary)

• UK competent authority granted a grace period to adapt labelling requirements. In September 2022, the original 2-year grace period has been extended to 5 years.
• Therefore, there is a 5-year grace period (until December 31, 2025) for the labelling of cosmetic products (Article 19 (1)(a) transitional arrangements UKCR);
• Name, address and country of origin requirements are satisfied if they comply with Article 19 of the EU Cosmetics Regulation;
• Thus, products with EU RP on the pack can be made available on the UK market until December 31, 2025. From January 1, 2026, UK Responsible Person shall appear on the labels;
• However, there is no transition period for artwork if the previous EU RP was based in the UK.