What is the UK Cosmetics Regulation, and how do you stay compliant?

The UK Cosmetics Regulation (UKCR) is the retained version of EU Regulation 1223/2009 brought into UK law by the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019. It applies to every cosmetic product placed on the Great Britain market and is enforced by the Office for Product Safety and Standards (OPSS) together with local Trading Standards. The framework is structurally identical to the EU regime (safety assessment, Responsible Person, notification, labelling, GMP) but operates a separate UK authority, a separate notification portal and a separate set of ingredient annexes that are slowly diverging.

Every cosmetic product placed on the GB market must have a single UK Responsible Person (UKRP) established in the United Kingdom. The UKRP is the legal entity accountable for safety, compliance, PIF custody, SCPN notification and engagement with OPSS and Trading Standards.

The UKRP is the manufacturer (if UK-based), the importer (if the product is imported into GB), or a third party appointed in writing. An EU-based Responsible Person is no longer sufficient for GB sales, even if the same product is legally sold in the EU under its EU RP.

Before a cosmetic product is placed on the GB market the UKRP must notify it via the Submit Cosmetic Product Notifications (SCPN) portal operated by OPSS. The submission covers product category, frame formulation, labelling, presence of nanomaterials, CMR substances and the contact details of the UKRP. Any substantive change (formula, labelling, RP) requires an updated notification.

SCPN is structurally similar to the EU CPNP but is a different portal, with different login, different data schema and different update cadence. Products sold in both jurisdictions need both notifications, kept in sync.

The Product Information File (PIF) must be held by the UKRP and made available to OPSS on request. It contains the product description, the Cosmetic Product Safety Report (CPSR, parts A and B), the method of manufacture and a GMP declaration (typically ISO 22716), proof of claimed effect and any animal testing data. The CPSR must be signed by a suitably qualified safety assessor. The PIF should be kept for ten years after the last batch is placed on the market.

The two regimes started identical and are now drifting. Live divergence points include:

• Separate updates to Annex II (prohibited) and Annex III (restricted) substances. The UK has not adopted every recent EU amendment and has made its own decisions on substances such as certain hair-dye ingredients and preservatives.
• Separate timelines for CMR substance reviews under Article 15.
• UK-specific labelling: the address of the UKRP must appear on the pack, and the responsible person reference defaults to the UK entity.
• Separate notification portal (SCPN vs CPNP) with separate accounts and data formats.

You cannot assume an EU-compliant product is UK-compliant. The gap widens with each annex update.

Under the Windsor Framework, the EU Cosmetics Regulation continues to apply to products placed on the Northern Ireland market. Products moving GB to NI are treated as entering the EU market, which means an EU Responsible Person, CPNP notification and EU labelling. Most brands selling UK-wide end up maintaining a UKRP for GB and an EURP for NI/EU simultaneously.

The pragmatic answer is to hold one product master tagged against both regimes. Formula, INCI, frame formulation, CPSR and labels live once. Regulatory overlays for EU and UK sit on top, surfacing divergence (banned in UK but not EU, different concentration limits, RP address differences) as alerts before submission. This is how Worldover handles it: one product record, two notifications, no parallel spreadsheet.