Tag: brexit

The UK Regulation, The cosmetic regulation after BREXIT

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Are you selling your cosmetic products in the UK? Have you already found your Responsible Person to sell your cosmetic products in the UK? We can help you with everything you may need when placing your cosmetic products in the UK!

Cosmeservice offers its services from Great Britain with the aim to provide support to cosmetic companies to have a Responsible Person in this country, as required by the new cosmetic regulation after Brexit. Of course, Cosmeservice will continue to have their headquarters in the European Union, in Spain so, in this way, British companies interested in operating on European soil will be able to count on the same services that they have been offering up to you now too.

The United Kingdom has made some modifications 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 labelling of the product, and the notification, which must be carried out from now on in the UK portal SCPN (Submit Cosmetic Products Notification). All these modifications started in 2021.

The countdown to notify your cosmetic products has begun! March 31st was the final date to transfer cosmetic products notified into the European CPNP (Cosmetic Products Notification Portal) to the British SCNP (Submit Cosmetic Products Notification).

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

Below, you will find in detail the consequences for cosmetic products that will be marketed in the UK market after the Brexit implementation:

1. RESPONSIBLE PERSON IN THE UK

Cosmetic companies (from all over the world) wishing to market their cosmetic products in the United Kingdom will be forced to have a responsible person located in the UK 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 representative there.

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.

The Responsible Person service will include:

  • A legal or natural person with a legal identity in the UK.
  • Compliance guarantor for Regulation requirements.
  • Expert in the registration process and preparing the required reports.
  • First point of contact for competent Health Authorities, in the case of an Inspection, or consumers, in the case of a complaint.
  • A single annual fee covers all the products we assess and notify into the SCPN (Submit Cosmetic Products Notification) under our name as Responsible Person, limited to just five brands.

2. PRODUCT INFORMATION FILE (PIF)

The PIF must be available at the address of the Responsible Person within the UK. Every cosmetic product must have its own Product Information File in English, containing all the information about the product, its method of manufacture and the UK Responsible Person.

This document must be kept up-to-date at all times and follow any changes in regulations, and it has to be available to the Health authorities up to ten years after the last product was commercialized.

At Cosmeservice, our internal Safety Assessors perform the product information file with the highest quality and professionalism.

3. SUBMIT COSMETIC PRODUCTS NOTIFICATION (SCNP)

From now on, the Responsible Person should notify information related to the cosmetic product to the UK. All this must be carried out through the new Submit Cosmetic Products Notification (SCNP).

What happens to pre-BREXIT notifications of the products already on the market? They can be easily transferred to the SCPN from the CPNP.
European companies interested in the market in the UK must notify from 1st January 2021 till the 31st March 2021 on the UK portal available for this purpose, to avoid any problem.

4. LABELLING

The name and address of the Responsible Person must be indicated on the label of cosmetic products. At the moment the UK withdraws from the EU, the products made on European soil and marketed in the UK will be treated as imported from a 3rd country.

We recommend you to choose a professional Responsible Person in Europe and the United Kingdom in order to unify all regulatory services in the same consulting company.
If you have any questions, please do not hesitate to contact us. We will be pleased to help you.

 

Cosmeservice – Responsible Person in Europe & the UK

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

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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.

Labelling

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

Brexit and what does it mean for the cosmetics industry

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What does the UK cosmetics landscape look like post Brexit and what does it mean for the industry?

Take a look at where we are now and what is to come in 2020.

The United Kingdom is set to leave the European Union tonight, on 31st January 2020 at midnight (Brussels time). The EU and the United Kingdom have conducted intensive negotiations to agree on the terms of the UK’s withdrawal and create legal certainty once EU law ceases to apply to the UK.

What’s next? Transition period

When the United Kingdom leaves the European Union on 31st January 2020, we will enter into the transition period. This time-limited period was agreed as part of the Withdrawal Agreement and will last until at least 31st December 2020. Until then, it will be business as usual for citizens, consumers, businesses, in both the EU and the United Kingdom, EU law will still apply in the United Kingdom until the end of the transition period.

Article 41 of the EU Withdrawal Agreement states that goods placed on the EU27 or UK markets before the end of the implementation period may be further made available and circulate between the two markets until they reach the end consumer. Proof of when the goods were placed on the market will be required.

The EU and the United Kingdom will use these months to agree on a new and fair partnership for the future, based on the Political Declaration agreed between the EU and the United Kingdom in October 2019.

What is the timeline of the transition period? Can it be extended?

The transition period starts on 1st February 2020, and will end on 31st December 2020, unless a decision to extend it is taken by mutual EU-UK agreement before 1 July 2020. Such an extension can only be decided once, for a period of 1 or 2 years.

There are unknown facts around the full impact Brexit will have on cosmetics regulation and compliance, but regulatory knowledge and harmonisation across the European Union must still be prioritised. During this year 2020 all kind of negotiations will take place, as the impact this would have on the cosmetics industry, particularly regulation and compliance, is not yet fully clear.

What will happen if the responsible person for the cosmetics products is based in the United Kingdom?

As we already know, as from the withdrawal date, authorised representatives that are established in the United Kingdom will not be recognised as authorised representatives for the purposes of legislation applicable to the EU on health products. Accordingly, manufacturers must take the appropriate measures to guarantee that, as from the withdrawal date, their authorised representatives are established in the EU-27.

What about goods placed on the market?

The Withdrawal Agreement provides that goods lawfully placed on the market in the EU or the United Kingdom before the end of the transition period may continue to freely circulate in and between these two markets, until they reach their end-users, without any need for product modifications or re-labelling.

This means that goods that will still be in the distribution chain at the end of the transition period can reach their end-users in the EU or the United Kingdom without having to comply with any additional product requirements. Such goods may also be put into service (where provided in the applicable provisions of Union law), and will be subject to continued oversight by the market surveillance authorities of the Member States and the United Kingdom.

What repercussions will Brexit have on the CPNP notifications for cosmetics products?

Whether or not a Brexit agreement is approved, the new EU-27 responsible entity will need to file notification of the product with the CPNP before introducing the cosmetics product into the EU-27 market after the withdrawal of the UK from the EU.

For cosmetics products manufactured in the United Kingdom, the notification will need to state that they are imported from the United Kingdom.

What repercussions will Brexit have on cosmetics PIF?

Whether or not a Brexit agreement is approved, the data files on cosmetics products will need to be available at the address of the EU-27 responsible entity and will need to be drawn up under the necessary terms in the language of the Member State in question after the withdrawal of the UK from the EU.

What repercussions will the withdrawal have on cosmetics product labelling?

Whether or not a Brexit agreement is approved, cosmetics product labelling must include the name and address of the responsible entity.

Following the withdrawal, any cosmetics products manufactured in the United Kingdom and marketed in Europe will be considered as cosmetics products imported into the EU-27 from a third country. The country of origin will therefore need to be indicated on the labelling.

Keep calm, but be prepared.

The transition period starting on 1st February 2020 will give the companies a period to adapt and find the best solution for its businesses, looking forward to the terms of the final agreement.

Please note – during the implementation period, while the UK will be officially out of the EU, EU law will still be applicable in the UK. In practice, this means that companies will continue to operate during the implementation period itself as they have in the past; however, companies are recommended to use this time to prepare for what is to come.

This means that in the short term (at the end of the implementation period) UK law will be constituted of retained EU law, therefore a ‘replica’ of EU law, with some differences in some mechanisms that depend on the outcome of the negotiations.

All information we catch up about Brexit and UK Cosmetic Legislation will be shared, just be aware!

More information: Cosmetic Regulation POST – BREXIT, Everything you need to know

Cosmetic Regulation POST – BREXIT, Everything you need to know

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As you may know, the United Kingdom submitted on 31 October 2017 the notification of its intention to withdraw from the European Union (Brexit).

This means that as from 1 november 2019, 00:00h (CET) (‘the withdrawal date’) the United Kingdom will be a ‘third country’.

Preparing for the withdrawal is not just a matter for EU and national authorities but also for private parties. In view of the uncertainties surrounding the ratification of the Withdrawal Agreement we want to highlight one point: the EU rules in the field of cosmetic products will no longer apply to the United Kingdom.

This has in particular the following consequences for cosmetic products placed on the EU market as of the withdrawal date:

  1. RESPONSIBLE PERSON

According to the Regulation (EC) No 1223/2009, only cosmetic products for which a legal or natural person is designated within the EU as ‘responsible person’ shall be placed on the market.

As of the withdrawal date, responsible persons can no longer be established in the United Kingdom.

If you are working with an UK Responsible Person, don’t wait until the last moment to get ready, contact us.

  1. NOTIFICATION IN THE COSMETIC PRODUCT NOTIFICATION PORTAL

According to the Regulation (EC) No 1223/2009, prior to placing the cosmetic product on the market, the responsible person shall notify a list of information relating to the cosmetic product to the Commission, through the Cosmetic Product Notification Portal (CPNP).

As of the withdrawal date, prior to placing a cosmetic product on the EU-27 market, the new responsible person in the EU-27 will have to make product notifications in the CPNP.

As regards existing notifications made before by a responsible person established in the United Kingdom, the CPNP offers the possibility to transfer notifications to another responsible person. Later, the former UK-based responsible person will no longer have access to the CPNP.

  1. PRODUCT INFORMATION FILE (PIF)

According to the Regulation (EC) No 1223/2009, when a cosmetic product is placed on the market, the responsible person shall keep a product information file (PIF) for the cosmetic product.

As of the withdrawal date, the PIF has to be made available at the address of the responsible person in the EU-27.

  1. LABELLING

According to the Regulation (EC) No 1223/2009, the name and address of the responsible person shall be indicated on the label of cosmetic products. The country of origin shall be specified for imported cosmetic products.

As of the withdrawal date, cosmetic products manufactured in the United Kingdom and placed on the EU market will be a cosmetic product imported into the EU-27 from a third country.

This information and will be updated with further information, where necessary if the ratification of the Withdrawal Agreement finally takes out successfully. At the moment, is not the case.

Now, the spotlight is on The United Kingdom due to the last announcement of the Prime Minister, which allows, at first, to rule out a sudden break at the end of next month.

COSMESERVICE is very attentive to updates in cosmetic regulation. Because of that, we recommend you to choose us as your responsible person in Europe. If you have any doubt or concern, please contact us. We will be more than glad to help you.

Cosmeservice- EU Responsible Person