1) What are the different deadlines for label compliance for cosmetics in the UK?
From 1st January 2021, companies marketing cosmetic products in the UK must comply with the requirements of the new UK Cosmetics Regulations.
Existing products benefit from a grace period of 90 days from the end of the transition period to be notified on the UK SCPN (United Kingdom Submit Cosmetic Products Notifications). In this case, the notification is simplified: the amount of information required is relatively small.
Existing products are defined as products that:
- were previously notified to the European Union via the CPNP (Cosmetic Product Notification Portal),
- were already available on the EEA or UK markets before 31st December 2020,
- will be placed on the UK market within 90 days of the end of the transition period.
As far as the actual labelling of cosmetic products is concerned, there are two possible cases:
- If the products were marketed before 31st December, 2020, then the labels do not need to be changed and can be sold while stocks last.
- On the other hand, products placed on the British market from 1st January 2021 have 2 years from that date to bring their labels into compliance with the British cosmetic regulations. This provision is, of course, subject to compliance with all other points of the legislation (responsible person based in the UK, notification to the UK SCPN, etc.).
2) What information must appear on the label of cosmetics sold in the UK?
Must appear on the labels of cosmetic products sold in the United Kingdom:
- The name and address of the responsible person based in the United Kingdom,
- Quantity declaration
- PAO (Period after Opening) or minimum durability date if applicable,
- Warnings and precautions,
- The batch number,
- The function of the product,
- The declaration of ingredients,
- The country of origin for imported products.
All this information must be written clearly and indelibly in English.
3) Does the address of the UK Responsible Person (RP) have to appear on the label?
Yes, the name and address of the responsible person based in the UK must appear on the label by the deadlines mentioned above.
4) Can a sales manager be appointed as the person responsible in the UK?
The issue is not specifically addressed in the regulation. However, please note that the responsible person will need to have access to the cosmetic Product Information File. They will also need to be able to answer questions from the authorities in the event of an inspection. These questions may be particularly technical and concern the scientific reasoning of the product safety report, for example. This is why we recommend you to be particularly careful in choosing your responsible person.
5) Are multilingual labels allowed?
Yes, multilingual labels are allowed provided that all mandatory information for each market is visible in the required languages.
6) After December 2022, will it be possible to put a sticker on the labels of products sold in the UK?
This is not recommended. It is not specifically stated in the regulations whether it will be accepted, however we advise you to take advantage of the 2 year grace period granted by the UK government to bring your labels fully into compliance. You can also rely on consultants such as EcoMundo to review your labels for both the European and UK markets. Indeed, December 2022 marks the deadline by which your products will have to comply.
7) What about batches of cosmetic products placed on the British market before the end of the transition period?
Cosmetic products placed on the market before the end of the transition period (until 31st December 2020), complied with the legislation in force at the time of their marketing. For this reason, the UK government does not impose a product recall and they can therefore be marketed without any concerns, as long as they are notified in time on the UK SCPN.
Wish to know more about the compliance of cosmetic products ?
For more information, do not hesitate to contact Nataliya Muller or one of our experts!
