Following its withdrawal from the European Union, the United Kingdom will surely be considered as a third country, from the deadline onwards. Meaning that any UK-based company will then need to appoint a Responsible Person inside EU-27 so as to remain compliant with the legislation and continue to sell within the Union.
According to the European Commission, a company importing products made in the United Kingdom will - by default - become the Responsible Person. However, they can appoint, in writing, another person established in the European Union.
EcoMundo can become your Responsible Person right after the UK leaves the EU, thereby putting our expertise and experience at your disposal.
With the UK’s exit, CPNP notifications made prior to the Brexit, by British Responsible Persons (RPs), must be transferred to the future RPs above mentioned. Nevertheless, the Commission states that such a transfer will only be possible until the effective date of Brexit (29th March 2019 or end of December 2020). Past this deadline, UK-based RPs will no longer have access to the CPNP.
EcoMundo recommends that you anticipate as much as possible this responsibility transfer in order not to be caught off guard when the decision is made effective.
An evolving communication
The Product Information File (PIF) will need to be stored by the new Responsible Person, and will also have to be available in the member country’s language. To be prepared for any eventuality, you will have to arrange for a “double DIP”, in English.
Products' labelling will probably also need to be ajusted after Brexit. Products manufactured in the United Kingdom will have to be re-labelled as imported products. They will need to show, in compliance with the legislation, the origin country (here, the United Kingdom) and the name and address of the EU-27 Responsible Person.
A scenario subject to conditions
This scenario might come into place as soon as the end of March 2019, if the treaty negotiated between the United Kingdom and the European Union fails to be ratified by one of the two Parliaments (British or European). The British Parliament should vote between January 7th and January 27th, 2019; and only at that point will we have a clear and definite vision on what happens next.
If the transition period planned by the treaty is adopted, the due date will be postponed to the end of December 2020. At this point, new proceedings will be negotiated by the EU and the UK regarding the applicable norms.
EcoMundo will keep you posted on the matter, do not hesitate to keep checking regularly our blog and social media - Twitter, Linkedin and Facebook - to stay up to date on all the information about this tricky topic.
Want to know more on Brexit and the cosmetics sector?
For more information on EcoMundo's services and software for your cosmetic products' compliance, do not hesitate to contact our expert, Sylvain De Backer by phone at : +33 1 83 64 20 54 for Europe, or +1 (778) 234 1607 for North America or even send him an email at [email protected].
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