Cosmeservice opens an office in the UK to help companies cope with cosmetic regulation after BREXIT

Cosmeservice will also offer its services from Great Britain with the aim that cosmetic companies can have a Responsible Person in this country, as required by the new legislation after Brexit.

Likewise, the Spanish company that is an expert in cosmetic safety and regulation, Cosmeservice will continue to have its headquarters in the European Union. In this way, British companies interested on operate on European soil will be able to count on the same services that they have been offering up to now.

Great Britain has made some alterations to the European Cosmetic Regulation (EC) document No 1223/2009 to create its own UK Cosmetic Regulation document. These changes affect the Responsible Person, the PIF, the labeling, and the notification, which must be carried out from now on in the UK portal. All these modifications will start in 2021.

How to prepare to market cosmetic products in and from the UK after Brexit

Below, we detail the consequences for cosmetic products marketed in the EU and UK markets after the Brexit implementation:

Responsible Person

European companies (and from all over the world) wishing to sell their cosmetic products in the United Kingdom will be forced to have a responsible person in this country, in accordance with the existing Regulation as of 1st of January in the United Kingdom. That is, they will have to designate a natural or legal person there.

On the other hand, British cosmetic companies that market their products in Europe must also have the same figure, but in the EU.

As a way of making this procedure as simple as possible, Cosmeservice has established a new office in the UK to provide this service to companies that are interested in it. Do not hesitate to contact us to request more information from our experts.

Cosmetic Products Notification Portal (CPNP)

From now on, the Responsible Person should notify information related to the cosmetic product to the European Commission. All this must be carried out through the Cosmetic Products Notification Portal (CPNP).

What happens to pre-BREXIT notifications by a Responsible Person in the UK? The responsible person in Great Britain may transfer the notifications to another in Europe. However, the former will no longer have access to the CPNP.

Likewise, European companies interested on market in the EU must notify from 2021 on the UK portal available for this purpose, called UK Submit Cosmetic Product Notification (SCPN).

Product Information File (PIF)

From the beginning of the BREXIT, the PIF must be available at the address of the Responsible Person within the European Union. The same would happen to the contrary with companies from Europe in the United Kingdom.


The name and address of the Responsible Person must be indicated on the label of cosmetic products. The moment Britain withdraws from the EU, those products made on British soil and marketed in Europe will be treated as imported into the EU-27 from a 3rd country.

From COSMESERVICE, we recommend you to choose us as your Responsible Person in Europe and in the United Kingdom. If you have any questions, please do not hesitate to contact us. We will be pleased to help you.

Cosmeservice – Responsible Person in Europe

SUNSCREENS. All you need to know about SPF and its compliance with EU requirements.

Do you want to avoid any inconvenience or problem with your SPF-PA certificate? Join our new webinar about SPF (Solar Protection Factor) and its compliance with EU requirements.

Do you know what is ultraviolet radiation and how it affects the skin? What is the solar protection factor and how is it measured? What is a photoprotector? What are the ultraviolet filters allowed by European regulation? All these questions will be answered during our new free webinar!

We have deep experience performing SPF (Solar Protection Factor) testing, and we have worked with the most important cosmetic clients around the world! The process is easy and simple, and our team will explain to you every step, to justify the claims and protect your final consumer.

This webinar is part of a series of free webinars offered by Cosmeservice as the expert company in European Cosmetics safety and regulation. It will take place on January 20 at 9 AM (CET).

You can access to this live webinar on the date indicated through the following link:

Register at 9:00 CET / 16:00 KST

New webinar. Sustainable Cosmetics: Does Natural really mean Sustainable?

Could we say that every natural product is considered sustainable? what is understood by Sustainable Cosmetics? what strategies can we take into account to achieve a Sustainable Product? Some of these questions are key to designing a sustainable product.

Cosmeservice organizes a webinar whose objective will be to solve myths about what is usually understood as Natural Cosmetics and Sustainable Cosmetics. Here, in addition, some strategies will be defined to take into account when developing a Sustainable Cosmetic Product.

This webinar is part of a series of free webinars offered by Cosmeservice as the expert company in European Cosmetics safety and regulation. It will take place on December 16 and the users who participate will be able to enjoy two different hours, one at 9 AM and the other at 6 PM (Spanish time).
Access to this live webinar would be possible on the date indicated through the following links:

Register at 9:00 CET / 16:00 KST

Register at 18:00 CET / 9:00 PDT

Easy guideline about claims for Hydro-Alcoholic Hands Gel

As of now, some labeling elements will be forbidden in the context of the Covid-19 pandemic. Claims, references, and pictures will be affected by this Technical Document.

Introduction to the previously published legislation

Following the spread of the Coronavirus (COVID-19) disease, many actions have been carried out in EU to prevent and reduce the transmission of the virus. This includes enhanced hygiene practices. As preventive measure against the spread of Coronavirus (COVID-19) disease, the European Centre for Disease Prevention and Control recommends “Washing of hands with soap and water for at least 20 seconds, or cleaning hands with alcohol-based solutions, gels or tissues is recommended in all settings”.

The use of hand cleaners and hand disinfectants in forms of gels, hand wipes or other leave-on products has increased dramatically across most EU countries, and a lot of companies are investing in the production of Hand cleaners and Hand disinfectants to respond to the additional needs.

A steep increase in the submission to the Cosmetics Product Notification Portal under the Cosmetics Regulation of hydroalcoholic gels was noticed, and clear guidance for manufacturers on the applicable legislation and related requirements was published on 30th March 2020. In particular, while normally soap is a cosmetic product, other products such as alcohol-based solutions, gels, hand-cleaners, hand-disinfectants, etc. might require further clarification.

Sometimes it may be unclear whether a particular product is a cosmetic product, falling under cosmetics legislation or whether it falls under other sectorial legislation. In the case of Hydroalcoholic gel, this product can be classified as a cosmetic product or as a biocidal one, depending on the intended use.

The decision on a product’s classification must be taken at first stage of production, to evaluate the safety of the product properly, to perform the different tests needed, and to select the claims that will be placed at the label.

These products can be subject either to Cosmetic Products Regulation or Biocidal Products Regulation (normally only one legislation should be applicable to a product). This depends first of all on the presence of an active substance and the main purpose of the product:

  • Products supplied with a main or exclusive cosmetic purpose (i.e. cleaning or cleansing the skin notably in absence of water rinsing) are covered by the Cosmetics Regulation.
  • Products containing an active substance and supplied with a primary biocidal purpose (i.e. intended to control harmful organisms) are not covered by the cosmetics legislation and therefore fall within the scope of the biocides legislation.

Practical examples

Although the claims themselves are not the only decisive factor whether the product should be considered as covered by the Cosmetics Regulation or the Biocidal Products Regulation, they are a relevant indication of the purpose of the product. However, if the product is presented with a claim stating a biocidal action, it could be considered as biocidal.

Examples include products containing an active substance and making a claim to improve public health through the control of infectious organisms, such as “disinfecting”, “kill viruses”, “kill bacteria”, which would go beyond the general perception of personal hygiene and can include antibacterial hand gels.

It is therefore important to look at all the characteristics of the product, and in particular its composition, the purpose and the function of the product. If it is clear that the product is mainly intended to protect public health through biocidal action (e.g. disinfecting, antimicrobial/virus function), which would go beyond the general perception of personal hygiene, and the objective criteria for considering such a product as “biocidal product” are fulfilled, the product cannot be considered as a cosmetic product and will have to comply with the Biocidal Products Regulation.

The European Commission has drawn up a technical document on the legislation that applies to cleaners and disinfectants that do not require a hand rinse. These changes affect the labeling elements that would not support the main cosmetic function of these leave-on gels.

We want to help you have everything under control! Because of this, we have created this quick table to answer your questions in just a moment. You can find listed the claims, references or pictures that cannot be used at cosmetic products, at leave-on hydroalcoholic hand gels.

The recently published technical document should be read taking into account the Borderline Manual and the “Guidance on the applicable legislation for leave-on hand cleaners and hand disinfectants”, as it aims to complement these documents.

Even if the classification of each product shall be conducted on a case-by-case basis, taking into consideration all characteristics, product claims (to be intended as text, names, trademarks, pictures and figurative or other signs) can, nevertheless, be a strong indication of the main purpose of a product.

If you have any questions or concerns about this, contact us. We will be glad to help!