Cosmetics regulation post-Brexit

Brexit & EU and UK cosmetics regulation

Last week the UK confirmed that agreed Brexit deal between the EU and the UK, and today it was also confirmed by the EU parliament, which means that Brexit will take place as scheduled – on 31.1.2020.

What does this mean for your EU and UK cosmetics compliance and of course sales of your cosmetic products? Initially, nothing changes. After Brexit, there will be a transitional period when the EU and the UK will try to agree on the future trade relations, and that transitional period will last till the end of the year (although it will quite likely be extended by another year or 2). Till the end of the transitional period, the CPNP notifications and the EU RP are still valid for the UK as well, and the UK RPs can still act as the EU RPs.

After the transitional period ends though, you’ll need to get a UK based responsible person, do the UK product notification and make some changes on the labels, specifically:
– add the UK responsible person name and address
– since the UK will become a third country, products produced there and sold in the EU, will need to state “made in the UK” and vice versa for the products made in the EU

What are the timelines to appoint the UK RP, make the UK notification and update the labels?
– UK RP will have to be appointed at least till the end of the transitional period
– UK notification will have to be done in up to 3 months after the end of the transitional period
– Labels will have to be updated in up to 2 years from Brexit

Besides that, the cosmetics legislation in the EU and in the UK will remain the same for now. Future changes in the legislation may happen though.

CE.way has set up a subsidiary in the UK last year, so we can provide also the UK RP service and can do UK product notifications (once the UK notification portal becomes operational, at the moment it doesn’t exist yet). Contact us to get an offer if you’re interested in these services.