UK Cosmetic Compliance

Great Britain runs its own cosmetic regime, separate from the EU since Brexit and now diverging from it in substance. Selling a cosmetic in England, Scotland or Wales means meeting the UK Cosmetics Regulation, the version of Regulation (EC) No 1223/2009 assimilated into domestic law by Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, enforced by the Office for Product Safety and Standards (OPSS) and local Trading Standards under the Cosmetic Products Enforcement Regulations 2013. The structure still mirrors the EU Regulation, the same articles and the same annexes, but the two are no longer identical and the gap is widening.

The Responsible Person

Every cosmetic on the GB market must have a Responsible Person established in the United Kingdom (Article 4). The role can sit with the manufacturer, the importer or a distributor, or it can be delegated to a third party by written mandate, but the address must be in the UK. The Responsible Person holds the legal obligations set out in Article 5: ensuring a compliant safety assessment is in place, holding and maintaining the Product Information File, making the SCPN notification, ensuring the labelling and claims comply, operating cosmetovigilance, and taking corrective action and notifying OPSS where a product is non-compliant or presents a risk. A GB distributor importing from outside Great Britain becomes the Responsible Person unless another UK entity takes the role. Oxford Biosciences acts as UK Responsible Person, and as EU Responsible Person, under a single quality management system.

The Cosmetic Product Safety Report

Safety is substantiated through a Cosmetic Product Safety Report under Article 10 and Annex I. Part A assembles the safety information: the quantitative and qualitative composition, the physico-chemical characteristics and stability, the microbiological quality, the impurities and traces, information on the packaging material, normal and reasonably foreseeable use, exposure to the product and to each substance, the toxicological profile of the ingredients, and any undesirable effects. Part B is the assessor’s reasoned conclusion on safety, the labelled warnings and the reasoning behind them. Annex I requires the assessment to be carried out by a person holding a qualification in pharmacy, toxicology, medicine or a similar discipline; ours are prepared and signed by a Clinical Pharmacologist.

The Product Information File

The Responsible Person keeps a Product Information File under Article 11, holding the product description, the safety report, a description of the manufacturing method with a statement of compliance with good manufacturing practice, proof of the claimed effect where the nature of the claim justifies it, and data on any animal testing. It must be kept in English, held readily accessible at the address shown on the label, and retained for ten years after the last batch was placed on the market, available to OPSS on request.

Notification through SCPN

Before a product is sold it is notified through the Submit Cosmetic Product Notification (SCPN) portal, the GB counterpart to the EU’s CPNP. The notification covers the product category and name, the Responsible Person’s details, the frame formulation, the presence of any CMR substances and nanomaterials, and the label and product image, so that OPSS and the poisons services hold what they need. SCPN and CPNP are separate systems: a CPNP notification does not cover Great Britain, and an SCPN notification does not cover the EU.

Labelling

Article 19 sets the mandatory label elements: the Responsible Person’s name and UK address, the nominal content, the date of minimum durability or the period-after-opening symbol, precautions for use, the batch number, the product function, and the list of ingredients by INCI name in descending order of weight. The defining GB requirement is the address, which must be that of the UK Responsible Person. A post-Brexit easement that allowed an EU Responsible Person address to remain on GB-market packs has been winding down, so UK Responsible Person details on pack are now expected rather than optional.

Cosmetics are not UKCA-marked

Cosmetics do not carry UKCA or CE marking. Those marks belong to other product families, such as electronics, toys and medical devices, that demonstrate conformity through a marking regime. A cosmetic demonstrates compliance through its safety report, its SCPN notification and its Responsible Person, not a conformity mark, so a request for a “UKCA certificate” on a cosmetic is a category error rather than a missing document.

Divergence and the 2026 changes

The clearest sign that the two regimes have parted is SI 2026/23, the Cosmetic Products (Restriction of Chemical Substances) (Amendment and Transitional Provisions) Regulations 2026, laid on 15 January 2026 on the advice of the Scientific Advisory Group on Chemical Safety. It removes the UV filter 4-methylbenzylidene camphor (4-MBC) from the permitted UV-filter list in Annex VI and prohibits it in Annex II: it cannot be placed on the GB market from 15 July 2026, with a sell-through to 14 January 2027. It adds sixteen substances newly classified as carcinogenic, mutagenic or reprotoxic to the prohibited list from 15 August 2026, with a sell-through to 14 February 2027, the cosmetically significant one being trimethylbenzoyl diphenylphosphine oxide (TPO), used in gel and nail products. And it lowers the threshold at which a formaldehyde-releasing substance must carry a consumer warning to 0.001 per cent. None of this applies in Northern Ireland, which follows the EU regime under the Windsor Framework, so a product sold across the whole United Kingdom can face two different sets of annexes at once. Further reviews, PFAS among them, are expected, so the divergence will grow rather than settle.

How we help

We act as your UK Responsible Person, prepare and sign the CPSR, compile and hold the Product Information File, make the SCPN notification, and review labelling and claims against Article 19 and the Common Criteria. Because the GB and EU annexes are now moving apart, we keep each assessment current against the GB position and flag where a product sold in both Great Britain and the EU or Northern Ireland needs checking against both, against the 2026 dates in particular.