UK-based RP and RP by default
Non-UK manufacturers wishing to place a cosmetic product on the UK market need to have already appointed a UK based Responsible Person on 1 January 2021
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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
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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;
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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;
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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;
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The UK’s notification portal requires the following information:
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Products’ name and category;
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The Responsible Person name and address and contact details of a natural person;
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The products’ frame formulation
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The name and address of the UK RP must be on the product label (both primary and secondary)
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There is a 2-year grace period (art.19 UKCR) for the labelling of cosmetic products;
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Products with EU RP on the pack can be made available on the UK market for 2 years counting from 1st January 2021. From 1 January 2023, UK Responsible Person shall appear on the labelling;
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However, there is no transition period for artwork if the previous EU RP was based in the UK.
What does it mean?
This mechanism involves a high degree of risk for non-UK manufacturers, who might find the representation of their products to be left to non-professional RPs with:
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Little to no knowledge of the new regulatory requirements in the UK;
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No knowhow of representation before the competent authorities;
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No awareness of their newfound role.
What should you do?
To avoid these risks, cosmetic products manufacturers should appoint a professional UK-based RP who can advise them on the regulatory compliance of their products, notify their products and handle all aspects of representation to the authorities. You can do it in two easy steps:
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Sign an UK RP Agreement with Obelis UK;
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Provide Obelis UK with a list of your UK distributors, so that Obelis UK can contact them and make arrangements for the delegation of the RP by default role of the distributors to the professional RP (Obelis UK).