Sell Cosmetics in the UK: Post-Brexit Compliance Guide

• Great Britain has operated a separate cosmetics regime under the UK Cosmetics Regulation (UKCR) since 1 January 2021 — EU rules no longer apply in GB, and a CPNP notification does not cover the GB market.
• Products placed on the GB market must be notified through the SCPN portal (free, pre-market) — a system entirely separate from the EU's CPNP; both notifications are required for brands selling in both markets.
• A UK Responsible Person established in Great Britain is required; a separate EU RP is still needed for the EU market; Northern Ireland follows EU rules under the Windsor Framework.

Last reviewed: June 2026

1. Three territories, three rule sets

The United Kingdom's departure from the European Union on 1 January 2021 created a three-territory compliance map that does not exist anywhere else in Europe. Understanding which rules apply where is the essential starting point.

The Northern Ireland situation is frequently misunderstood. Under the Windsor Framework (the successor agreement to the Northern Ireland Protocol), Northern Ireland remained aligned with EU single market rules for goods, including cosmetics. A product sold in Northern Ireland is treated as if it were sold in the EU: it must carry a CPNP notification and an EU/NI Responsible Person. The UK Cosmetics Regulation and SCPN apply to Great Britain only.

For an EU brand entering the UK market, the Ireland guide offers useful context: selling cosmetics in Ireland is the English-speaking EU entry point, and many brands use an Irish RP to cover the entire EU market before adding a separate UK RP for GB.

2. The UK Cosmetics Regulation (UKCR) and OPSS

The UK did not create an entirely new cosmetics law after Brexit. Instead, the EU Withdrawal Act 2018 retained Regulation (EC) 1223/2009 as it stood on exit day, converting it into domestic UK law. Administrative modifications were made by The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/696), Schedule 34 — replacing references to EU institutions and member states with UK equivalents.

The result is called the UK Cosmetics Regulation (UKCR). It is structurally identical to the EU regulation: the same product categories, the same safety assessment framework (PIF + CPSR), the same Annex structure for permitted/prohibited/restricted substances. Over time, the two bodies of law are diverging as the UK enacts independent Statutory Instruments — see §6 for the current divergence table.

The competent authority under the UKCR is the Office for Product Safety and Standards (OPSS), an executive agency of the Department for Business and Trade (DBT). OPSS receives SCPN notifications, handles serious undesirable effect (SUE) reports, advises on enforcement, and amends the UKCR through Statutory Instruments based on advice from the Scientific Advisory Group on Chemical Safety in Consumer Products (SAGCSC).

OPSS contact: opss.enquiries@businessandtrade.gov.uk

For SUE reports (equivalent to cosmetovigilance): seriousundesirableeffects@businessandtrade.gov.uk

3. SCPN — notify cosmetics for Great Britain

The Submit Cosmetic Product Notifications (SCPN) portal is the UK equivalent of the CPNP for Great Britain. It launched on 1 January 2021, the day the EU CPNP ceased to cover GB.

Portal URL: https://submit.cosmetic-product-notifications.service.gov.uk

Key facts:

• Cost: Free — no notification fee
• Account: Requires a GOV.UK One Login account
• Timing: Must notify BEFORE placing the product on the GB market (pre-market obligation)
• Territory: Applies to Great Britain only; Northern Ireland uses the EU CPNP
• Independence from CPNP: The two systems are entirely separate and do not share data. A valid CPNP notification does not cover GB; a valid SCPN notification does not cover the EU or NI.

Information required for each SCPN notification includes: product category and name, UK Responsible Person details and address, location of the product information file (PIF), emergency contact information, nanomaterial declarations, CMR substance disclosures, ingredient summary, label image, and packaging photographs.

Brands that held CPNP notifications before 1 January 2021 were required to re-notify their entire GB product portfolio on SCPN by 31 March 2021. Any products notified only on CPNP and sold in GB after that date without a corresponding SCPN notification are non-compliant.

Penalties for non-compliance: Unlimited fine in England and Wales; up to £5,000 in Scotland and Northern Ireland, plus up to 3 months' imprisonment.

4. The dual Responsible Person

Under both the EU framework and the UKCR, every cosmetic product must have exactly one Responsible Person (RP) — the entity that takes legal accountability for the product's compliance.

For brands selling in both the EU and Great Britain, this creates a dual-RP requirement:

1. EU Responsible Person: Must be established in the EU/EEA. Registers the product in the CPNP. Accountable under Regulation (EC) 1223/2009 — see the Responsible Person obligations guide for the full EU-side framework.

2. UK Responsible Person: Must be established in Great Britain with a genuine UK address — not a mail forwarding service, not a PO Box. Registers the product in the SCPN. Accountable under the UKCR.

The two roles are independent and non-interchangeable. An EU RP address does not satisfy the UK requirement; a UK RP address does not satisfy the EU requirement. The same legal entity can act as both RP roles only if it has genuine establishments in both jurisdictions.

Northern Ireland RP: Products sold specifically in Northern Ireland require an RP established in Northern Ireland or the EU/EEA. A Great Britain-only address does NOT qualify for the NI market. In practice, many brands use a single Irish or EU-based RP to cover both the EU and Northern Ireland simultaneously.

5. Labelling and the PIF in Great Britain

Language

All mandatory label elements under the UKCR must appear in English. This includes: the name and UK address of the Responsible Person, nominal content, minimum durability date or period after opening (PAO), precautions for use, product function, batch number, and the ingredient list (INCI names, which remain exempt from language requirements as international nomenclature).

Country of origin

When a product is manufactured outside of Great Britain, the label must state the specific country of manufacture — for example, "Made in France" or "Made in Germany". The statement "Made in the EU" is not acceptable under the UKCR. This is a notable divergence from some earlier practices.

UK RP address transition period

There is a transition period allowing products to continue to display an EU Responsible Person address on GB packaging:

• Current deadline: 31 December 2027 (basis: Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 — SI 2022/1393)
• Until that date, products may show an EU RP address on GB packaging provided the product entered GB after 1 January 2021 and EU contact details are shown
• Note: this deadline has been extended before; monitor OPSS announcements for any further extension
• From 1 January 2028 (unless extended again): GB packaging must show a UK RP address exclusively

Product Information File (PIF)

The UKCR requires the same PIF structure and CPSR content as the EU regulation. Specific UK requirements:

• The PIF must be maintained in English at the UK RP's address
• Retention period: 10 years from the date the last batch was placed on the GB market
• Safety assessor qualifications: university degree in pharmacy, toxicology, medicine, or equivalent (EU qualifications are accepted)

For ingredient data in the PIF — INCI names, CAS numbers, function classifications — the CosIng database remains a reference source, though UK-specific restrictions may go beyond it (see §6).

6. Where UK and EU rules diverge

The UKCR and EU Regulation 1223/2009 started from the same text on 1 January 2021. Since then, both regimes have enacted changes independently, creating a growing list of divergences. The table below contains only SI-verified entries — restrictions confirmed from UK legislation.gov.uk sources.

Last updated: June 2026 — this table is time-sensitive; verify OPSS Statutory Instruments for changes after this date.

The Pentasodium Pentate / Pentetic Acid divergence is particularly notable for formulators: a product compliant in the EU may not require any change for the UK market for these specific substances, while a product that was reformulated for the EU ban may have changed unnecessarily if it is sold only in the UK.

This guide does not include comparisons of UK fragrance allergen labelling requirements versus EU Regulation 2023/1545 — those specifics are not fully verified from primary sources at time of writing.

7. Frequently asked questions

Is my CPNP notification valid in the UK? No — not for Great Britain. A CPNP notification covers EU member states only. Products placed on the GB market must be separately notified through the SCPN (Submit Cosmetic Product Notifications) portal before being placed on the GB market. The two systems are entirely separate and do not share data. For Northern Ireland, however, the CPNP remains the required portal under the Windsor Framework.

Can one Responsible Person cover both the EU and the UK? No. A brand selling in both the EU and Great Britain requires two separate Responsible Persons: an EU RP established in the EU/EEA and registered in the CPNP, and a UK RP established in Great Britain with a genuine UK address. The same person or entity can fulfil both roles only if it has a genuine establishment in both jurisdictions. A Great Britain address does not qualify for Northern Ireland — NI requires an RP established in Northern Ireland or the EU.

What changed for cosmetics regulations after Brexit? From 1 January 2021, Great Britain left the EU single market for cosmetics. The UK retained Regulation (EC) 1223/2009 as domestic law (the UK Cosmetics Regulation / UKCR) via the EU Withdrawal Act 2018, modified by SI 2019/696, Schedule 34. The key operational changes are: (1) GB notification now goes to the SCPN portal instead of CPNP, (2) a UK Responsible Person with a genuine GB address is required, (3) labels must show an English-language UK RP address (transition until 31 December 2027), and (4) the UK is diverging from EU regulations through independent Statutory Instruments.

Does Northern Ireland follow UK or EU cosmetics rules? EU rules. Under the Windsor Framework (successor to the Northern Ireland Protocol), Northern Ireland continues to apply EU Regulation (EC) 1223/2009 directly. Products placed on the NI market must be notified via the CPNP, and the Responsible Person must be established in Northern Ireland or the EU/EEA — a Great Britain-only address does not qualify.

What is the process for SCPN notification and is there a deadline? SCPN notification is free and must be completed before placing any cosmetic product on the GB market. You need a GOV.UK One Login account to access the portal at https://submit.cosmetic-product-notifications.service.gov.uk. Required information includes product category and name, UK Responsible Person details, PIF location, ingredient summary, nanomaterial declarations, and label/packaging images. Brands already notified on the CPNP before Brexit were required to re-notify on SCPN by 31 March 2021. There is no ongoing annual fee or renewal — SCPN is a one-time pre-market notification per product.