UK cosmetics regulation: selling skincare legally in Great Britain

The legal basis in Great Britain

Before Brexit the UK applied the EU Cosmetics Regulation. At the end of the transition period on 31 December 2020, the regulation was copied into UK law and adapted by Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/696). Since then it is called assimilated law, and the UK changes its annexes with its own statutory instruments.

• Scope. The GB regulation covers England, Wales and Scotland. Northern Ireland is covered separately (see below).
• Regulator. The Office for Product Safety and Standards (OPSS), part of the Department for Business and Trade, runs SCPN, receives serious undesirable effect reports and advises ministers on ingredient changes, using advice from the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS).
• Enforcement. The Cosmetic Products Enforcement Regulations 2013 make the Secretary of State and local weights and measures authorities, known as Trading Standards, the enforcement authorities in GB, and district councils in Northern Ireland.

The structure is the same as in the EU: no pre-market approval, one Responsible Person per product, a safety report, a product file and a notification. If you know the EU system, read our EU cosmetics regulation guide and then focus on the differences here.

The UK Responsible Person

The assimilated Article 4 says a cosmetic may not be placed on the market unless there is a responsible person established in the United Kingdom. OPSS guidance adds that the RP must have a UK established address, and that mail forwarding and PO box addresses do not count.

OPSS lists the RP's duties: make sure products are safe, know the ingredients and their restrictions (including harmful substances and nanomaterials), keep the PIF up to date, make the packaging, labeling and instructions clear, notify OPSS before sale, report serious harmful effects and be able to substantiate marketing claims. An EU Responsible Person does not satisfy GB law, and a GB RP cannot act for the EU or Northern Ireland.

Step by step: from formula to legal GB sale

The example is a centella toner made in Korea, sold through a Shopify store and Amazon UK.

1. Appoint the UK RP

   Sign a written mandate with a UK-established person. Their name and UK address go on the label, so do this before artwork.

2. Check the formula against the GB annexes

   Use the GB text of Annexes 2 to 6 on legislation.gov.uk, not the EU text, and check the statutory instruments listed in the divergence table. Colorants, preservatives and UV filters must be on the GB positive lists (Annexes 4, 5 and 6).

3. Collect safety data

   Formula, raw material data, stability, challenge test, microbiology, impurities and packaging specification, as in the EU.

4. Get the safety report

   Part A from the data, Part B signed by a qualified safety assessor.

5. Approve the GB label

   UK RP name and address, country of origin, English text and the rest of Article 19.

6. Assemble the PIF in English

   Held by the RP and available to OPSS and Trading Standards.

7. Notify on SCPN

   Before the product is made available to GB consumers. If it contains a nanomaterial that needs its own notification, that is due at least 6 months before placing on the market.

8. Import

   A GB EORI number, the import declaration and import VAT. The business steps, costs in pounds and duty are in our guide to starting a skincare brand in the UK and the business setup guide.

The safety report and PIF

The GB safety report follows Annex 1, the same structure as the EU CPSR. OPSS describes it this way:

• Part A, prepared by the RP: ingredients, stability, microbial contamination, packaging, likely use and exposure.
• Part B, prepared by a qualified safety assessor: the safety conclusion, any warnings, the scientific reasoning, and the assessor's details and qualifications. The assessor should hold a degree in pharmacy, toxicology, medicine or a similar discipline.

The Product Information File must be kept in English for every product and holds the product description, the safety report, evidence of good manufacturing practice and evidence of the effects claimed. OPSS says it must be kept for 10 years after the last batch was made available. GMP can be shown through ISO 22716, though OPSS notes it is not the only route.

Can one report serve the EU and GB? The science is the same, and many assessors issue a report that covers both, but each must name the right RP and check the formula against the right annexes. Because the annexes have diverged, a formula that passes in GB may fail in the EU, and the reverse.

SCPN notification

The RP submits each product on the Submit Cosmetic Product Notification service, signing in with GOV.UK One Login. The service is free. GOV.UK lists what you need:

• the category and name of the product;
• the name of the RP and where the PIF is kept;
• a named contact for urgent enquiries;
• any nanomaterials and any CMR substances;
• the chemical details of substances and a summary of the ingredients;
• an image of the label and a photograph of the packaging.

SCPN data is not public. It is used by Trading Standards and the National Poisons Information Service. An EU CPNP notification does not count in GB, and SCPN does not cover Northern Ireland. More on the two portals in what a CPNP number is.

Where GB rules now differ from the EU

Since 2021 the EU and GB amend their annexes separately. The table lists the GB statutory instruments we found on legislation.gov.uk for 2023 to 2026, with their dates.

EU changes GB has not adopted, as of October 2026. Among the instruments we checked, none brings in the EU's vitamin A limits (0.05% and 0.3% retinol equivalent), the EU alpha-arbutin and arbutin limits, the EU genistein and daidzein limits, or the expanded EU fragrance allergen list of Regulation (EU) 2023/1545; GB still uses the original allergen list. The EU REACH microplastics restriction (Regulation (EU) 2023/2055) does not apply in GB, which runs its own UK REACH; plastic microbeads in rinse-off personal care products have been banned since 2018 under separate environmental regulations in each GB nation. Check UK REACH news from the Health and Safety Executive before relying on this.

Timing differences. TPO was banned in the EU from 1 September 2025 with no sell-through, and in GB from 15 August 2026 with stock allowed until 14 February 2027. 4-MBC left the EU market on 1 May 2026 and leaves GB shelves by 14 January 2027. Kojic acid has the same 1% face and hand limit in both, on different dates.

OPSS consults on changes before they are made, often citing EU and SCCS opinions, so more alignment may come. Check legislation.gov.uk and OPSS before each formula freeze. Our reformulating for the US and EU guide covers multi-market formulas.

The GB label

The assimilated Article 19 requires the UK RP's name and address, the country of origin for imported products, the weight or volume, the date of minimum durability or period after opening, precautions, the batch number, the function and the ingredient list, with nanomaterials marked "(nano)". The Cosmetic Products Enforcement Regulations 2013 require the content, durability, precautions, function and related information to be in English. The full label list, with small-pack rules, is in our label requirements by country; ask for our label proof check before printing.

A pack sold in GB and the EU can carry both an EU RP and a UK RP. Many brands print both addresses on one label to run one SKU across markets.

Northern Ireland and the Windsor Framework

Under the Windsor Framework (the revised Northern Ireland Protocol), the EU Cosmetics Regulation continues to apply in Northern Ireland. OPSS guidance says the Responsible Person for products sold there must be established in Northern Ireland or the EU, and products are notified on the EU CPNP, not SCPN. A GB-only RP and SCPN notification do not cover NI. District councils enforce the rules there.

So a brand selling across the whole UK needs: a UK RP (for GB) plus an NI or EU RP (for NI), an SCPN notification plus a CPNP notification, and a formula that meets both the GB and the EU annexes.

Claims, advertising and the medicine borderline

• Claims. Article 20 and the assimilated Regulation (EU) No 655/2013 apply: claims must meet the six common criteria (legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making), and the RP must hold the evidence.
• Advertising. Ads, social posts and influencer content are policed by the Advertising Standards Authority under the CAP Code, which demands documentary evidence for objective claims. See our FTC and ASA advertising guide.
• Medicines. Products presented as treating or preventing disease are medicinal products regulated by the MHRA under the Human Medicines Regulations 2012, not cosmetics. "Treats acne" or "cures eczema" crosses the line. Sunscreens are cosmetics in GB, with UV filters from Annex 6; see our sunscreen guide.

SUEs, recalls and enforcement

• Serious undesirable effects. A SUE is one where normal or reasonably foreseeable use results in temporary or permanent functional incapacity, disability, hospitalization, congenital anomalies, an immediate vital risk or death. OPSS asks for reports immediately, using its SUE form, to seriousundesirableeffects@businessandtrade.gov.uk, with the RP details, the effects, the product name and batch number and any corrective measures. Minor effects such as irritation do not need a report.
• Corrective action. When a product is non-compliant or unsafe, the RP brings it into line, withdraws or recalls it, and informs the authorities where there is a risk to health.
• Safeguarding. If an authority finds a technically compliant product that still poses a serious risk, it must consult OPSS before acting.
• Enforcement. Trading Standards can test products, require information, issue notices, order withdrawals and prosecute offenses under the 2013 Enforcement Regulations.

The full incident plan is in our recalls and adverse events guide.

What your RP does and what we provide

Frequently asked questions

Sources

• legislation.gov.uk: SI 2019/696, Schedule 34 (amendment of Regulation (EC) No 1223/2009)
• legislation.gov.uk: Regulation (EC) No 1223/2009 as it applies in GB (Articles 4, 16, 19)
• OPSS: Making cosmetic products available to consumers in Great Britain
• GOV.UK: Submit a cosmetic product notification
• OPSS: SUE and safeguarding notifications for cosmetics
• OPSS: Regulation 1223/2009 and the Enforcement Regulations 2013, Northern Ireland and Cosmetic Products Enforcement Regulations 2013
• legislation.gov.uk GB statutory instruments: SI 2023/836, SI 2024/455, SI 2024/1334, SI 2025/413, SI 2025/901, SI 2026/23, SI 2026/109
• EUR-Lex: Regulation (EU) 2024/996 and Regulation (EU) 2025/877 (EU dates used for comparison)

Checked against these sources in October 2026. Rules and fees change; check with the authority or your importer before you sell.