June 1, 2020
Considerations for the transition period & beyond
The UK has now left the EU, but as far as cosmetics are concerned its business as usual until the end of the transition period on December 31, 2020. After this time, EU regulation 1223/2009 on cosmetics products will no longer be in force in the UK, meaning the following:
- To market cosmetic products into the EU from the UK, you will need to appoint a responsible person (RP) in the EU. Importers of products from the UK into the EU will automatically be considered as the RP.
- All existing cosmetic products notification portal (CPNP) notifications for products that will continue to be sold into the EU after the transition period must be transferred from the UK RP to the EU RP before the transition period ends. A new UK CPNP will be established, though it is currently unavailable to access.
- Product Information Files PIFs must be available in the language required by the EU member state of the RP address.
- The name and address of the EU-based RP must be present on all product labelling.
- Product safety assessments must have been carried out by a safety assessor who held qualifications recognized by an EU member state at the time of the product being placed on the market. Qualifications from the UK that have not been recognized as equivalent by an EU member state will no longer be valid.
- Products sold into the EU or UK markets before the end of the transition period (proof will be required) may be made further available in either market and circulate between them until reaching end users.
- As per the EI/NI protocol, EU cosmetic regulation EC 1223/2009 will still apply to Northern Ireland. This means products sold into NI will need to comply with the regulation, products made in NI and shipped to the EU will not be treated as imports, UK products sold into NI will be treated as imports, and an EU RP may be established in NI.
How Exponent Can Help
Exponent can act as an RP in the EU, and all our safety assessors have EU-recognized qualifications. We can fully support UK companies wishing to market cosmetic products into the EU. Our Cosmetic Regulatory Team has over 20 years of experience working across all areas of the personal care industry including product development, distribution, and manufacturing of cosmetic and toiletry products. Based in the UK, the Exponent Regulatory Team can act as your responsible person for all your cosmetic and toiletry needs or provide contract and ad-hoc regulatory services.