What is going to be the consequence of Brexit for the labelling of aerosols in the UK?

Labelling of Aerosols – UKCA Mark

In September 2020, a guidance was issued on the use of the UKCA mark from January 1, 2021, as a substitute for the CE mark on the UK market. Something remarkable of this guidance is, while the applicability of the UKCA mark had previously been established for products that currently have the CE mark, this guidance states that it will also apply to aerosol products.

It is to be borne in mind that the CE mark is currently not being applicable to all aerosols in the EU – e.g. some are regulated under the EU Cosmetics Regulation,  but only to those aerosols that are classified as products for which the CE mark is mandatory.

Initially, the UK Aerosols Regulation, namely Schedule 13 of the Product Safety and Metrology (UK Aerosols Regulation), provided for the UKCA mark or the reversed epsilon symbol (currently required under the EU Aerosol Dispensers Directive) to be affixed on the pack, as either of them would have been accepted as a self-certification that the aerosol complies with the relevant regulatory standards. However, this alignment no longer exists.

The above does not render the use of the reverse epsilon (3) banned on aerosols sold in the UK, but they will have no significance under the UK framework.

Requirement of the UKCA mark for aerosols – deadlines

Schedule 13 of the Product Safety and Metrology SI gives the provisions for the UK Aerosols Regulations (Amendment No 7), imposing the requirement of the UKCA mark for aerosols;

The aforesaid has been ultimately backed up by the recently published guidance onRegulation 2009/1223 and the Cosmetic Products Enforcement Regulations 2013 As they apply to cosmetic products being supplied in or into Great Britain from 1 January 2021, as they apply to which contends that ‘’for cosmetic products contained in also aerosol dispensers, the aerosol dispensers will need to meet the requirements of the Aerosol Dispensers Regulations 2009, which includes the requirement to mark the dispenser with UKCA compliance mark, which is replacing the reversed epsilon mark’’.

According to the guidance, there is a dual recognition of the reversed epsilon (“3”) – until 31 December, 2021. From 1 January, 2022, it will be compulsory to switch to the UKCA marking, and until 31 December, 2022, the UKCA marking may appear on a label affixed to or a document accompanying the aerosol dispenser. From 1 January, 2023, the UKCA marking will generally need to be affixed directly on the product.

Carlos Francisco Marín Barrios

Regulatory Affairs Department


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