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Brexit update for Cosmetic Manufacturers



At the time of writing there is no confirmed trade deal between the UK and the EU. However, we now have confirmation of the Statuary Instrument (SI) Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019. This was introduced in the case of a no deal outcome in 2019 and will come into force on the 1st January 2021. There will be further SI’s to implement technical modifications but in essence the Regulation will remain. The outcome of the trade talks will have little effect on the Regulations.

What will not change:

The requirement for a Responsible Person (RP), a Cosmetic Product Safety Report (CPSR), a Product Information File (PIF) and notification on a cosmetic portal. Labelling requirements will undergo some small some amendments.

What will change:

A UK based RP will no longer be able to sell cosmetic products in the EU. The Cosmetic Product Notification Portal (CPNP) registration of all UK based RP’s will be deleted on the 1st January 2021. An EU based RP will no longer be able to sell cosmetic products in the UK. A UK Notification system will be in place on the 1st January 2021. If you live in Northern Ireland things are slightly different and I will come to that later.

What you need to do:

All UK based RPs must download an .xml file of their current CPNP notifications before January 1st, 2021. Create a new account on the UK notification system. Keep the .xml file on hand as you will be able to upload the file directly to the new system. This will save uploading each product individually. The UK notification system will be live as from 1st January 2021. There will be a 90-day grace period to upload to the new system (1/1/21 – 1/4/21) after which cosmetics sold without notification will be illegal.

If you wish to sell in both the UK & EU, an EU based RP will be required as well as a UK RP. Both address’s need to be on the label. For products destined to be sold in the EU, the RP address for the EU must be underlined and vice versa for the UK. This includes products sold online.

Northern Ireland (NI):

If you live and sell cosmetics in NI, you must adhere to the EU Cosmetics Regulations. For the purposes of EU legislation, NI is considered as being part of the EU. A NI address will enable you to sell cosmetic products in the EU.

If you wish to sell cosmetics in the UK, you will need to comply with both UK & EU legislation and notify on both CPNP and the UK notification system.

Finally:

If you live in the UK and wish to sell cosmetic products in NI, you will need an EU based RP and both the RP address’s must be on the label along with Manufactured in the UK.

If you have any questions, please email verdigris@me.com


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