It’s finally happened—the United Kingdom has left the European Union and “Brexit” is law. Whatever your views on this, it will impact cosmetic regulations in the EU and the UK, with the deadline for compliance of the new rules taking effect December 31, 2020. Let’s cover the current information on how Brexit will affect cosmetics in terms of regulations and exports.
As you likely know, when shipping goods into the EU you are required to have a “Responsible Person” who is located there and can act as your representative. If your current Responsible Person is not in the UK, nothing really changes.
However, if you are exporting to the UK and/or the EU or have a UK-based Responsible Person, your cosmetic information, labeling, and more will change. Here are the major differences:
- You will need a separate Responsible Person for the UK and another for the EU. If you currently have a Responsible Person in the UK to broker imports to the EU, you will need to find someone else in the new legal borders by December 31st, 2020.
- Your Product Information File, or PIF, for both the UK and the EU will need updating. Because these files (labels) require your Responsible Person to be identified, you will likely need to print new labels to cover updated information. For a little more on labels in the US with the FDA, check out this blog.
- Each product will need to be registered twice, once in the UK and once in the EU.
- Given that the UK has relied on the EU to help determine policy for the roughly the past 45 years, the UK will now have to create new cosmetic regulations. It is certainly possible that the UK will keep the EU standards (1223/2009), but it may be rewritten.
- New types of borders have now been created—any ingredients shipped between the EU and UK for manufacturing purposes will now be subject to different customs protocol.
- Underlying this whole transition process is the understanding that chemical and ingredient criteria for cosmetics may change in the UK now that Brexit is officially underway.
- One note of continuity: at this time it is assumed that UK-based Safety Assessors will still be able to assess EU products.
- Additionally, English will remain an acceptable language for the EU
There are several questions left open at the moment—your guess is as good as ours, but we will do our best to stay on top of the upcoming changes. When you work with our custom manufacturing and private label departments we’re able to provide compliance checks and more, so we encourage you to reach out to our team with questions on how to get started!
