How will cosmetic products be regulated in the UK in case of a no-deal Brexit?
Preparing for different Brexit scenarios, the UK government published a guidance covering the EU Exit Regulation for Cosmetic Products in case UK leaves the European Union without a deal. While there are many similarities between the EU and UK regulatory regime for cosmetic products, the withdrawal of the UK from the European Union without a deal will bring about several noticeable changes for manufacturers.
To place a cosmetic product on the UK market, a Responsible Person established in the UK must be assigned for that product. The cosmetics’ manufacturer or importer established in the UK will automatically be considered the Responsible Person. However, the manufacturer and the importer may designate a third party to act as the Responsible Person by means of a written mandate.
A mandatory notification of cosmetic products will be the responsibility of the Responsible Person and shall be performed through a cosmetic product registration portal put in place by the UK government:
- A transitional period of 90 days beginning with the exit day allows a simplified notification procedurefor those products:
- Already notified to the European Commission through the Cosmetics Product Notification Portal (CPNP);
- Made available on the EEA or UK market prior to the exit day;
- Placed on the UK market within 90 days of exit.
- Products being introduced for the first time in the UK market after the exit day will have to comply with the full notification as per the UK requirements.
The UK government has also put in place transitional arrangements regarding certain labelling requirements. Identical to the EU Regulation, the UK law will require the name and address of the RP and the country of origin to be labelled on cosmetic products placed on the UK market. However, for a transitional period of 2 yearsbeginning the day after the exit day, these UK requirements will be considered as satisfied when the labelling complies with the EU Cosmetics Regulation. These transitional arrangements will ease and prevent immediate labelling changes for EU compliant manufacturers.
Hannah Van Deun
Research & Development (R&D) Department
October 4, 2019
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