Cosmetics Personal Care
UK cosmetics regulation is not simply EU regulation with a different logo. Post-Brexit divergence is real, it is growing, and it catches out brands who assume the two frameworks still match.
The UK Cosmetics Regulation is being amended independently of the EU position. Ingredient restrictions, labelling requirements, and enforcement priorities are diverging. A product fully compliant in the EU is not automatically compliant in the UK and vice versa.For brands selling in both markets, this is an active operational gap. Products get removed from the UK market because brands assumed EU compliance was sufficient. OPSS does not notify you before it acts.
Every cosmetic product sold in Great Britain must have a UK Responsible Person: a natural or legal person established in the UK who is legally accountable for the product's compliance. Every product must have a Cosmetic Product Safety Report prepared by a qualified assessor. Every product must be notified through the SCPN portal before it goes on sale. Every product must meet UK labelling requirements including INCI ingredient listing, allergen declarations, and mandatory warnings.
The Product Information File must be held at the UK Responsible Person’s address and made available to authorities on request.
Relying on an EU Responsible Person for UK compliance post-Brexit, using outdated CPSRs that do not reflect current requirements, INCI listing errors or incomplete allergen declarations, claims that do not align with UK regulatory expectations. These are recurring gaps that can delay market access or lead to enforcement action if not addressed.
We also advise brands managing dual UK/EU compliance: where the frameworks still align, where they are diverging, and how to manage both without duplicating effort unnecessarily.