Brexit and Dual-Market Compliance

Two regimes, one product

Since 1 January 2021, Great Britain and the European Union have run separate cosmetic regimes. They began as near-identical copies of Regulation (EC) No 1223/2009, but they are now diverging in substance, not just administration, so a product sold in both has to satisfy two sets of rules that are moving apart. The science behind a safety assessment is shared, but the legal infrastructure, the Responsible Person, the notification, the label, and increasingly the permitted ingredients, has to be built twice.

Two Responsible Persons

Each market needs a Responsible Person established within it: one in the United Kingdom for the GB market and one established in the Union for the EU market. A single address cannot serve both, and a post-Brexit easement that allowed an EU Responsible Person address to remain on GB-market packs has been winding down. Oxford Biosciences acts as both UK and EU Responsible Person, the latter through our company registered in the Republic of Ireland, under one quality management system, so the dual obligation is held in one place rather than split across two providers.

Two notifications

The product is notified separately in each market: through the Submit Cosmetic Product Notification (SCPN) portal in Great Britain and through the Cosmetic Products Notification Portal (CPNP) in the EU. The two are independent. A CPNP notification does not place a product on the GB market, and an SCPN notification does not place it on the EU market, so a brand selling in both makes both filings.

One safety assessment, two annex checks

A single Cosmetic Product Safety Report can underpin both markets, prepared and signed by the assessor against both regimes, but the formulation has to be checked against both sets of annexes, and those annexes now differ. Great Britain has prohibited the UV filter 4-MBC and sixteen CMR substances and tightened formaldehyde-releaser labelling under SI 2026/23, while the EU has made its own changes through Omnibus VIII (Regulation (EU) 2026/78) and the ingredient Omnibus (Regulation (EU) 2026/909). The practical consequence is that a product can be compliant on one side of the divergence and not the other, so a dual-market assessment flags exactly where the two regimes part company.

Labelling for each market

The label follows Article 19 in both regimes, but the Responsible Person details differ: GB packs carry the UK Responsible Person’s name and UK address, and EU packs the EU Responsible Person’s details. Where the rest of the formulation and claims permit, a single artwork can carry both sets of details, but that is a decision to take deliberately rather than assume, particularly as ingredient and warning requirements diverge.

Northern Ireland and the Windsor Framework

Northern Ireland is the exception within the United Kingdom. Under the Windsor Framework, cosmetics placed on the Northern Ireland market follow the EU regime, including the EU annexes, an EU Responsible Person and CPNP notification, so a product sold in Northern Ireland is treated as an EU product rather than a GB one. Great Britain, meaning England, Scotland and Wales, follows the assimilated UK Cosmetics Regulation. A brand selling across the whole United Kingdom therefore spans both regimes at once.

How we help

We hold both the UK and EU Responsible Person roles under one system, prepare a single CPSR that addresses both regimes, make both the SCPN and CPNP notifications, and review labelling for each market. Because the annexes are now diverging, we track both and flag where a product needs a different formulation, a different warning or a different position in Great Britain, the EU and Northern Ireland. CPSRs are from £70. All fees are exclusive of VAT.