The UK cosmetics sector has undergone a period of considerable regulatory change following Brexit, particularly in relation to product labelling. These adjustments have introduced distinct requirements for businesses trading in Great Britain (GB) versus Northern Ireland (NI), creating new layers of complexity. With extended transition periods still in play, evolving fragrance allergen regulations, and emerging innovations such as digital labelling, this is a critical juncture for manufacturers and importers to review their compliance processes. For consumers, being able to understand what appears on cosmetics packaging is increasingly important. This article outlines the latest developments in UK cosmetics labelling, offering clear guidance for industry stakeholders and practical tips for consumers.
Understanding Post-Brexit Labelling Requirements
Since leaving the EU, the UK has established its own regulatory framework for cosmetic products. In GB, cosmetics are governed by the UK Cosmetics Regulation (UKCR)—a retained version of the EU’s Regulation (EC) No 1223/2009—modified under the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019. Meanwhile, NI remains aligned with EU regulations due to the Northern Ireland Protocol.
Labelling Differences Between Great Britain and Northern Ireland
Great Britain
Products sold in GB must include the name and address of a UK-based Responsible Person. This individual or entity is accountable for ensuring the product meets safety and regulatory standards. The label must also state:
- Country of origin (for imported products)
- Nominal quantity
- Date of minimum durability or Period After Opening (PAO)
- Relevant warnings
- Batch number
- Product function
- List of ingredients using International Nomenclature for Cosmetic Ingredients (INCI)
Northern Ireland
Cosmetic products in NI require an EU or NI-based Responsible Person and must comply with the EU Cosmetic Products Regulation (EU CPR). NI businesses supplying qualifying goods to GB can continue using EU labelling without additional authorisation, though notification to the GB regulator via the UK Submit Cosmetic Product Notification (SCPN) service is required.
These parallel systems necessitate label customisation depending on the intended market—an added layer that businesses must carefully manage.
Transitional Arrangements
To support industry adjustment, the UK government has provided extended timelines. Businesses may continue using EU Responsible Person details on GB product labels until 31 December 2027, provided those products were placed on the GB market after 1 January 2021 and include the necessary EU contact details. This extension, formalised under the Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393), offers businesses additional flexibility to update packaging.
However, it is important to note that all products must otherwise comply with the UKCR requirements. The grace period primarily concerns the labelling of the UK Responsible Person and the indication of country of origin.
Concerns over Fragrance Allergens
Fragrance allergens represent a prominent safety consideration. An estimated 1% to 9% of individuals may experience allergic reactions to certain fragrance compounds. Under the UKCR, 24 fragrance allergens listed in Annex III must be declared on product labels if present at concentrations exceeding:
- 0.001% for leave-on products
- 0.01% for rinse-off products
Substances such as Linalool and Citral must be listed using their INCI names, in addition to the general term “Parfum” or “Aroma”.
In the EU, a recent regulatory update—Regulation (EU) 2023/1545, effective 16 August 2023—expanded the list to over 80 allergens, including additions like menthol and lemongrass oil. EU businesses have until 31 July 2026 to ensure new products are compliant, and until 31 July 2028 to sell existing stock.
The UK has not yet adopted this expansion. However, a joint statement issued in February 2025 by the Cosmetic, Toiletry and Perfumery Association (CTPA) and the International Fragrance Association UK (IFRA UK) suggests alignment may be forthcoming. The statement also clarified terminology related to “placing” and “making available” on the market—further indicating that changes could be on the horizon.
Practical Implications for Businesses
Remaining compliant with evolving labelling rules requires a strategic approach. Below are key actions for industry professionals:
- Appoint a UK Responsible Person:
This may be the manufacturer, importer, or a third party. Their UK address must be included on labels for products sold in GB. - Differentiate GB and NI Labelling:
Ensure GB products display UK Responsible Person details and country of origin. NI products must adhere to EU CPR rules, and EU-based labelling is acceptable for qualifying goods. - Monitor Allergen Labelling Developments:
Continue listing the current 24 allergens, and stay alert to potential changes. Expanded requirements could require product reformulation or label redesign. - Maximise the Grace Period:
Use the extended deadline (until end of 2027) to plan packaging updates in a cost-effective way—particularly if your products already meet EU labelling criteria. - Notify via SCPN:
For all GB-market products, ensure submission through the UK SCPN platform. NI businesses sending goods to GB must also submit relevant notifications.
Neglecting these requirements can result in regulatory penalties, recalls, or damage to brand reputation. Regular engagement with legal advisors or industry bodies such as the CTPA is highly recommended.
Emerging Trends in Cosmetics Labelling
Several developments are likely to influence cosmetics labelling practices in the UK over the coming years. Here’s a few:
- Smart Labelling
As the number of label-mandated allergens grows, packaging space is under pressure. The EU is currently piloting digital solutions—such as QR codes—to provide ingredient information accessible via smartphone. While this approach is not yet mandatory in the UK, it could offer a practical way to maintain compliance while improving transparency. Businesses should explore these tools proactively.
- Sustainability Regulations
The EU’s forthcoming Packaging and Packaging Waste Regulation (PPWR) aims to ensure all packaging is recyclable by 2030. It also introduces restrictions on per- and polyfluoroalkyl substances (PFAS) in cosmetics packaging. The UK may adopt similar sustainability measures. This would likely affect labelling, including possible requirements to display recyclability information or PFAS-free claims—both of which align with growing consumer expectations.
- Clean Beauty and Natural Claims
Consumers are increasingly drawn to products marketed as “natural” or “organic”. However, these terms are not specifically defined in UK legislation. Article 20 of the UKCR, alongside the Common Criteria for Cosmetic Claims, stipulates that such claims must be truthful, substantiated, and not misleading. While voluntary, ISO Standard 16128 offers a useful framework for defining natural and organic content. Using it to support claims on labels can help establish trust and ensure compliance.
Tips for Consumers
Understanding cosmetics labels empowers consumers to make informed decisions. Here are some key points to look for:
- Review the Ingredients List:
If you have known allergies, scan for substances like Linalool or Citral. These will follow the INCI format and typically appear after “Parfum”. - Check the Responsible Person Details:
A UK or EU/NI address signals that the product complies with the relevant regulations. - Read Durability Symbols Carefully:
Look for the “Best Before” date or the Period After Opening (PAO) symbol, such as “12M” (indicating the product is usable for 12 months post-opening). - Scrutinise Product Claims:
Be cautious with unregulated terms like “hypoallergenic” or “natural”. When in doubt, verify with credible sources or seek professional guidance.
Conclusion
Post-Brexit cosmetics labelling in the UK presents both challenges and opportunities. Businesses must navigate diverging GB and NI regulations, utilise transitional provisions wisely, and prepare for updates to allergen labelling. For consumers, label literacy supports safe and confident product use. As one of the largest suppliers of cosmetics labels in the UK we can certainly help with any questions that you have with your designs. Please contact us today for free consultation.
