Exporting Cosmetics to the UK: Responsible Person, SCPN, Labels, VAT

Great Britain: the law and the UK Responsible Person

In Great Britain, cosmetics are governed by Regulation (EC) No 1223/2009 as kept in UK law after Brexit (now called assimilated law), with the changes made by Schedule 34 to the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/696), and by the Cosmetic Products Enforcement Regulations 2013. The Secretary of State takes the place of the European Commission. The Office for Product Safety and Standards (OPSS) and local Trading Standards enforce the rules.

A product can be made available in GB only if it has a Responsible Person (RP) established in the UK. For an imported product, the UK importer is the RP, unless the manufacturer or importer appoints another UK-established person by written mandate. The RP can be a company or a sole trader, but its UK address cannot be a PO box or a mail-forwarding address. A brand outside the UK therefore cannot be its own RP; it uses its importer or distributor, or a UK RP service.

Not notifying a product is an offence. OPSS warns of a fine, unlimited in England and Wales or up to £5,000 in Scotland and Northern Ireland, and up to 3 months in prison.

Safety report, product file, GMP and animal testing

Before launch, a safety assessor qualified in pharmacy, toxicology, medicine or a similar discipline must assess each product and sign the Cosmetic Product Safety Report (CPSR). The RP keeps a Product Information File (PIF) in English for 10 years after the last batch was placed on the market, readily accessible to the authorities at the address notified. It contains the product description, the CPSR, the manufacturing method and a good manufacturing practice (GMP) statement, proof of claimed effects and data on any animal testing.

OPSS names ISO 22716 as the GMP standard, though other routes exist. A product cannot be placed on the GB market if its final formulation, ingredients or combinations of ingredients were tested on animals to meet the Regulation; historic animal test data from before the bans can still be used.

After launch, the RP must report serious undesirable effects to OPSS without delay. OPSS guidance reads this as within 30 calendar days of anyone in the company learning of a possible case.

SCPN notification and nanomaterials

Before a product is made available in GB, the RP notifies it through Submit cosmetic product notifications (SCPN), the OPSS service that replaced the EU's CPNP for GB. The service is free and needs a GOV.UK One Login account. An EU CPNP notification does not cover GB.

The RP gives the product name and category, its own details and the PIF address, a contact person, the ingredients or frame formulation, any nanomaterials and CMR substances, and an image of the label.

A product containing a nanomaterial that is not listed in Annexes 4, 5 or 6 (colourants, preservatives and UV filters) needs a separate nanomaterial notification at least 6 months before it is placed on the market.

Labels for Great Britain

The container and the outer packaging must carry the items below. Nominal content, durability, precautions and function must be in English, whether or not other languages also appear (regulation 5(3) of the Enforcement Regulations). Ingredients use the glossary of common ingredient names, based on INCI.

• Name and address of the UK RP. Until 31 December 2027, a label that meets the EU rule (EU RP name and address, country of origin) is accepted; from 1 January 2028 GB labels need the UK RP.
• Country of origin for imported products, naming a country such as Republic of Korea or Japan; OPSS does not accept "Made in the EU".
• Nominal content by weight or volume, except packs under 5 g or 5 ml, free samples and single-application packs.
• Date of minimum durability ("best used before the end of" or the hourglass symbol, then the date) if the product keeps 30 months or less; otherwise the period after opening (PAO, open-jar symbol with months).
• Precautions required by Annexes 3 to 6, on an enclosed leaflet or tag referred to by a symbol if space is short.
• Batch number or other code identifying the batch, and the function unless it is clear from the presentation.
• Ingredient list headed "ingredients", in descending order of weight (under 1% in any order), nanomaterials followed by "(nano)", fragrance as "parfum" or "aroma", colourants by CI number.

GB ingredient lists, the EU and Northern Ireland

GB started from the same Annexes as the EU: Annex 2 bans substances, Annex 3 restricts them, and Annexes 4 to 6 list allowed colourants, preservatives and UV filters. Since 2021 GB changes them by its own statutory instruments, on its own dates and often with sell-off periods the EU does not give. A product sold in both markets must meet both sets of lists.

Northern Ireland applies the EU Cosmetics Regulation under the Windsor Framework. A product needs an RP established in Northern Ireland or the EU, a CPNP notification and EU-compliant labels, and EU bans and the longer allergen list apply there. Products lawfully on the Northern Ireland market can be sold in GB as qualifying Northern Ireland goods; the RP only sends OPSS the same data through SCPN.

OPSS checks notifications against the GB lists. In 2025–26 it reviewed notifications for lilial (butylphenyl methylpropional), a banned fragrance ingredient, and targeted online sales of skin lighteners containing hydroquinone and of teeth whitening products with high hydrogen peroxide levels. Recent GB changes:

• Methyl salicylate limits, stricter for children aged 6 to 12 months, from 30 September 2025; earlier stock could be sold until 31 March 2026 (SI 2025/413).
• Benzophenone-3 (oxybenzone) limits from 21 January 2026; earlier stock could be sold until 21 July 2026 (SI 2025/901).
• 4-MBC (enzacamene) banned, and the "releases formaldehyde" warning needed where formaldehyde in the product exceeds 0.001%, from 15 July 2026; earlier stock may be sold until 14 January 2027 (SI 2026/23).
• TPO, used in gel nail products, and 15 other CMR substances banned from 15 August 2026; earlier stock may be sold until 14 February 2027 (SI 2026/23). The EU banned TPO from 1 September 2025 with no sell-off.
• Hexyl salicylate limits from 15 August 2026 (earlier stock until 14 February 2027), and 13 more CMR substances, including silver and ozone, banned from 23 March 2027 (earlier stock until 22 September 2027) (SI 2026/109).
• Fragrance allergens: the EU's longer labelling list (Regulation (EU) 2023/1545, from 31 July 2026) applies in Northern Ireland but had not been adopted for GB when this note was checked.

Customs: EORI, importer, duty, VAT and documents

The importer needs a GB EORI number, which a business usually gets only if it has premises in the UK. HMRC says that if you are not established in the UK and import goods into Great Britain, you can only ask someone to act indirectly on your behalf. A non-UK brand selling DDP therefore needs a UK indirect customs representative and usually a UK VAT registration; on FCA, FOB or DAP terms the UK buyer normally imports.

Typical headings are 3303 (perfumes), 3304 (make-up and skin care, including sunscreen), 3305 (hair products) and 3307 (shaving, deodorant and bath products); check the 10-digit code in the UK Integrated Online Tariff. Under the UK Global Tariff most 3303 to 3305 goods are duty free and most 3307 goods pay 6%. Korean goods can claim the UK–Korea FTA with an origin declaration on the invoice, made by an approved exporter if the consignment is worth over EUR 6,000; an upgraded agreement concluded in December 2025 was not yet in force when checked. The UK–India CETA has applied since 15 July 2026, and India can also use the Developing Countries Trading Scheme (DCTS) until 15 July 2028. There is no UK–China trade agreement, so Chinese goods pay the UK Global Tariff rate.

Import VAT is 20%. A UK VAT-registered importer can account for it on its VAT return (postponed VAT accounting); a non-established importer must instruct its agent in writing and be entered as consignee. On consumer sales in consignments of £135 or less, no import VAT is charged: the seller or online marketplace charges UK VAT at the point of sale. The £135 customs duty relief is to be removed on a date the Treasury sets, by October 2028 at the latest. Give the agent a commercial invoice in English showing seller, buyer, Incoterm, a clear description such as "face cream, 50 ml jars", commodity code, quantity, value, currency and country of origin, with a packing list of cartons and weights.