Changes in regulations for labelling products is something everyone’s familiar with, especially in the cosmetic business. Labelservice is here to help keep you up to date on these changes. With the exit out of the European Union, the United Kingdom is considered as a third country under the Cosmetics Regulation (EC) No 1223/2009. This means that, for a company based in the UK, it will now be necessary to have a Responsible Person in a country of the EU-27 to remain in compliance with the legislation and continue to market in the European Union. The company importing products made in the United Kingdom should, by default, become the Responsible Person, but may however designate in writing another person established in the European Union.
Notifications made to the CPNP (Cosmetic Products Notification Portal), by British Responsible Persons (RPs) will have to be supported by EU-27 based RPs. We recommend that you anticipate this transfer of responsibility as much as possible so that you are not caught unprepared.
The Product Information File (PIF) must be kept by the new Responsible Person and be available in the language of the RP’s member state in order to have products that comply with the European Cosmetics Regulation.
In addition, product labelling will also have to be adapted to Brexit. Products made in the UK and sold in Europe will have to be re-labelled as imported products. They will have to indicate, in accordance with the legislation, the country of origin (in this case, the UK), as well as the name and address of the Responsible Person established in the EU-27.
Northern Ireland, as part of the United Kingdom, also left the European Union upon Brexit. However, in order to avoid reviving the tensions on the border with the Republic of Ireland which had persisted for several decades and in which the European Union played a major role, the Northern Ireland Protocol was established.
In this, it is stipulated that, for trade with the United Kingdom, UK regulations would apply to Northern Ireland, and for trade with the European Union, EU regulations would continue to apply. We advise caution in this situation. Its continuity over time is still rather unclear. If you are established in these different markets, the safest thing to do is to comply with both EU and UK regulations. If you have any questions or concerns, please do not hesitate to contact our parent company Labelservice.