Brexit guidance for cosmetics
Brexit split one cosmetic market into two regimes that started identical and are slowly drifting apart. Here is what changed and what a brand needs in place.
What changed
Great Britain now operates the UK Cosmetics Regulation, the version of Regulation (EC) No 1223/2009 brought into UK 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. The EU continues under Regulation (EC) No 1223/2009 as before. The practical consequence is that the two markets now require separate compliance.
Two of everything, and Northern Ireland
Selling in both Great Britain and the EU means a UK Responsible Person established in GB and a separate EU Responsible Person established in the Union, two notifications (the SCPN in the UK and the CPNP in the EU), and labelling that carries the correct Responsible Person for each market. Northern Ireland follows the EU regime under the Windsor Framework, which brands selling UK-wide regularly overlook.
A widening gap
The rulebooks no longer move together. The 2026 GB amendment (SI 2026/23) bans the UV filter 4-methylbenzylidene camphor, lowers the formaldehyde-releaser labelling threshold and restricts further CMR substances on its own timetable, and chemical registration has split too, with UK REACH separate from EU REACH. A formulation compliant in one market is no longer automatically compliant in the other.
What we do
We act as both your UK and EU Responsible Person under a single quality management system, prepare both notifications, and keep your assessments aligned with each regime as it changes. For the operational detail of running across both, see our Brexit transition page, and for chemical registration our REACH compliance page.