Selling cosmetics in the EU and the UK after Brexit isn’t as straightforward as it used to be. While the rules might seem similar on the surface, crucial operational and legal differences can trip up even experienced brands. Ignoring them can lead to costly delays, fines, and even product recalls.
This guide is designed to help you cut through the complexity and understand what’s changed. We’ll look at the key requirements for both EU cosmetic regulations and UK cosmetic regulations, giving you a clear, practical plan for managing dual compliance. As a leading regulatory consultant, Russell Regulatory Consultants helps brands manage these daily challenges, turning potential obstacles into a clear path to market.
The Regulatory Demands of Shared History, Divergent Paths
Cosmetic regulation in Europe has a long history, and many of the UK’s rules today are based on that strong foundation. Following Brexit, the UK didn’t completely rewrite the rulebook. Instead, it assimilated the EU’s core legal text, Regulation (EC) No 1223/2009, into its own national law. This is good news for manufacturers, as fundamental requirements for product safety and quality remain largely the same.
For example, whether you’re selling a face cream in Paris or London, you still have to ensure it’s safe for human health. You’ll still need to follow Good Manufacturing Practices (GMP), and the standard for this, ISO 22716, is relevant for both markets.
However, this isn’t a guarantee of permanent harmony. By creating its own legal and technical infrastructure, the UK has set the stage for future regulatory divergence. This is why a proactive, dual-compliance strategy is so important.
Is the Northern Ireland Protocol a Shortcut or a Cosmetics Complication?
European cosmetic regulations and UK cosmetic regulations are further complicated by the Northern Ireland Protocol. Northern Ireland remains aligned with EU law for goods, including cosmetics. This creates a non-binary landscape where a business selling in Great Britain (England, Scotland, and Wales) must follow one set of rules, while a business selling in Northern Ireland must follow another.
The First Pillar: The Responsible Person (RP)
The Responsible Person (RP) is perhaps the most important legal role in cosmetic compliance. The RP is the legal or natural person with the ultimate legal obligation for all aspects of cosmetic safety. Their responsibilities range from ensuring your Product Information File is up-to-date to managing post-market vigilance.
Here’s where the EU vs UK cosmetics compliance really comes into play:
- For Great Britain: Products sold in England, Scotland, and Wales must have a UK Responsible Person established in the UK.
- For the EU and Northern Ireland: Products sold in these markets need an RP based in the EU or Northern Ireland.
This means a single RP can no longer cover both markets. If you’re a manufacturer based outside of the EU and UK, you’ll need to have a legal presence in both regions or, more commonly, hire two separate third-party RP service providers. That introduces new costs and administrative layers.
Related Reading: Understanding the Role and Responsibilities of the UK Responsible Person
Russell Regulatory Consultants specialises in providing reliable, expert UK Responsible Person services. Our team provides the local presence you need in the UK, helping you manage this complex responsibility effectively.
The Second Pillar: The Product Information File and CPSR
The Product Information File (PIF) is a mandatory dossier that must be prepared and maintained for every cosmetic product you market. It serves as your master technical document, holding all the information about your product’s safety, quality, and efficacy. You’ll need to keep it readily available for competent authorities for 10 years.
The great news is that the core content of the Cosmetics PIF is identical for both the EU and the UK. So, you only have to create one comprehensive dossier rather than two. The key difference is that the RP must hold and maintain the file in each respective jurisdiction.
The Cornerstone of Safety: The CPSR
The Cosmetic Product Safety Report (CPSR) is a legal requirement and the most critical part of your PIF. It’s the foundational document that proves your product is safe for human use. The content and structure of the CPSR are also largely harmonised across both markets, which is a big help for manufacturers.
However, there’s a crucial catch in the UK cosmetic regulations. A UK-based professional must sign the safety assessment. So, even if you have an EU-compliant CPSR, you’ll still need a UK-based assessor to review and sign off on it for Great Britain. This can be a point of confusion and delay for many brands.
Related Reading: Cosmetic Safety Assessments in the UK: What You Need to Know
At Russell Regulatory Consultants, we can help you with this by connecting you with a qualified UK-based assessor to ensure your CPSR is fully compliant with UK cosmetic regulations.
The Third Pillar: The Path to Market
Once your product is formulated, assessed, and documented, you must get it ready for sale. This involves two critical steps: notification and labelling.
A New Two-Portal System
Before Brexit, a single notification to the EU’s Cosmetic Products Notification Portal (CPNP) was enough to prepare a product for sale across the entire UK and EU. That’s no longer the case. The UK has created its own notification system, the Submit Cosmetic Product Notification (SCPN) service, which is “entirely separate” from the CPNP.
This means you now have to perform two distinct notifications:
- One for the EU and Northern Ireland via the CPNP.
- One for Great Britain via the SCPN service.
This fundamentally changes how regulators track and oversee products in their respective markets.
Labelling and Packaging Requirements
Cosmetic labelling requirements are a subtle but critical area of divergence. The most important difference is the RP’s address on the packaging.
- For Great Britain: Your packaging must display the name and address of your UK-based Responsible Person.
- For the EU: Your packaging must display the name and address of your EU-based Responsible Person.
This can be a significant logistical challenge. It means you may have to create separate product labels and stock-keeping units (SKUs) for each market, adding layers of complexity to your supply chain. We can help you manage this by advising on a compliant dual-labelling strategy that minimises costs and operational headaches.
Related Reading: The Complete Guide to UK Cosmetic Labelling Requirements (2025)
Post-Market Obligations: Continuous Vigilance (Cosmetovigilance)
Regulatory compliance doesn’t end when a product hits the shelves. Post-market surveillance (PMS) for cosmetics, known as cosmetovigilance, is a mandatory ongoing obligation in the EU and the UK. This system is a closed loop of continuous safety monitoring where the RP and distributors must review, report, and act on any undesirable or serious undesirable effects (SUEs) reported by consumers.
While the overall goal is the same for the European and UK cosmetic regulations, the reporting mechanisms are now distinct. You’ll need a system in place to handle separate reports for each market, providing data to your EU RP for EU authorities and your UK RP for the MHRA. The RP’s role as the national contact person is crucial for managing this dual-reporting reality.
Related Reading: UK Cosmetics Regulation: An Introduction for New Brands
Your Checklist for a Dual-Compliance Strategy
Managing EU vs UK cosmetics compliance requires careful planning. Here’s a quick checklist to help you create a proactive, systematic strategy:
- Appoint Dual Responsible Persons: A product for Great Britain needs a UK-based RP, while a product for the EU needs an EU-based RP. Russell Regulatory Consultants can provide this service for the UK.
- Prepare a Unified PIF: Create one master Product Information File that meets the requirements of the European cosmetic regulations and the UK cosmetic regulations. This will simplify your documentation process.
- Engage a Dual-Assessor Strategy: Even though the CPSR content is harmonised, the safety assessment for the UK must be signed by a qualified UK-based professional.
- Plan for Dual Notification: Products must be notified separately on the EU’s CPNP portal and the UK’s SCPN service.
- Implement a Dual-Labelling Strategy: Decide whether to use a single, dual-address label or create separate labels for each market to avoid non-compliance.
- Establish a Cosmetovigilance System: Ensure that adverse event reporting can be handled distinctly for each market, providing data to the respective RP and competent authorities.
The Path Forward for Cosmetics Compliance
The regulatory relationship between the EU and the UK for cosmetic products has a shared history but different paths. The UK’s decision to assimilate the EU’s foundational framework has created a relative alignment period, simplifying product formulation and claims substantiation.
However, the establishment of separate legal entities, technical systems, and enforcement bodies has created the infrastructure for a future of independent policy-making. For a compliance manager, the current situation is not a simple choice between one set of rules or another but a complex, dual-compliance reality that requires a more systematic approach.
At Russell Regulatory Consultants, we help cosmetic businesses confidently manage these challenges. From Responsible Person services to labelling advice and safety assessments, our team ensures your products are safe, compliant, and market-ready.
Book a free call with Russell Regulatory Consultants today to discuss your compliance needs
Article Sources
- legislation.gov. “Regulation (EC) No 1223/2009 of the European Parliament and of the Council.” Accessed 3rd September 2025
- ISO. “ISO 22716:2007.” Accessed 3rd September 2025
- Gov.uk. “Making cosmetic products available to consumers in Great Britain.” 4th October 2021
- National Library of Medicine. “Cosmetovigilance: A review of the current literature.” 8th May 2019
