On 1 January 2021, the UK Government department Office for Product Safety and Standards launched the UK cosmetic notification portal. The portal is called Submit Cosmetic Product Notification (SCPN), and it allows the notification of cosmetics products, which are made available to consumers in Great Britain (GB: England, Scotland, and Wales).
According to Article 13 of the UK Cosmetics Regulation (Schedule 34 to the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019), every cosmetic product has to be notified via SCPN before being placed on the GB market.
As is the case in the EU, the notification has to be done by the responsible person. The responsible person can be either the manufacturer, importer, distributor (if they label the product as their own) or a third party, who is appointed by the manufacturer or the importer.
To submit a cosmetic product notification via SCPN, you will require the following information:
- The category and name of the cosmetic product
- The name of the responsible person
- Where the Product Information File (PIF) is kept
- Details of a named contact for urgent enquiries
- Details of any nanomaterials the cosmetic product contains
- Details of any carcinogenic, mutagenic, or toxic for reproduction (CMR) substances the cosmetic product contains
- The chemical details of substances
- A summary of the ingredients
- A product’s label
- A photograph of the cosmetic product packaging.
For new products, which are being placed on the GB market after 31 December 2020 and have not been notified on the EU’s CPNP, you need to submit new notifications, which include the above-mentioned list of documents.
The notification has to be done before the products can be placed on the GB market.
For existing products, which are already present on the GB market and have been notified through the EU’s CPNP before 1 January 2021, the deadline for notification using the UK’s Submit cosmetic product notifications service is 31 March 2021.
The process of notifying the existing products is made easier by the possibility to upload the zip file of the EU notification to the SCPN. It is said that the portal allows uploads of 100 files at the time.
However, the uploaded zip files will not include any attached documents (such as the formulation and images) as well as details of any nanomaterials, which will have to be provided separately.
To summarise, below are the important dates concerning product notification in the UK:
- Existing products on the GB market, which have been notified using the EU’s CPNP portal before 1 January 2021: deadline for SCPN notification is 31 March 2021
- New products for the GB market: SCPN notification has to be done before products are placed on the market.
It is important to note that products placed on the Northern Irish market must be notified on the EU Cosmetic Products Notification Portal (CPNP), as Northern Ireland follows the EU Cosmetics Regulation No 1223/2009.
Labelling requirements
Companies that sell products on the GB market also have to keep in mind the new labelling requirements. All products sold in Great Britain need to bear the name and address of the UK Responsible Person from 31 December 2022. Although there is a grace period, we advise the companies to apply the changes as soon as possible.
There are two additional labelling requirements that need to be mentioned. One is the need to write the country of origin on the labels for all products made in the EU (by specifying the country).
And the last one is applicable only to aerosols, which under Schedule 13 of the Product Safety and Metrology SI require the addition of ‘UKCA compliance mark’.
This is an equivalent of the ‘reversed epsilon’, which is known under the EU cosmetics regulation.
The switch to the UKCA marking is compulsory from 1 January 2022. Until then, aerosols sold in GB can carry either the reversed epsilon or the UKCA mark.
Until 31 December 2022, the UKCA marking may be affixed to a label affixed to or a document accompanying the dispenser. From 1 January 2023, the UKCA marking must be affixed directly to the product.
