Owing to Brexit, the United Kingdom (UK) left the European Union (EU) on 31st January 2020. As part of the Withdrawal Agreement, the transition period has started immediately which will run up to 31st December 2020. CTPA being the UK trade association, represents the manufacturers of cosmetics as well as personal care products and suppliers to the industry and advises member manufacturers, distributors, and suppliers about the strict legal framework for cosmetics. While majority of the EC 1223/2009 regulations for the cosmetics are retained in the new laws for the UK, post Brexit, a few changes will be introduced in Cosmetics Regulations to align them with Brexit. Below are the possible post-Brexit changes
+ UK Responsible Person: Manufacturers will not be able to place a product in the UK market unless a Responsible Person based in the UK is appointed. However, manufacturers with existing cosmetic products in the UK will have a transition period of two years to update the label with the name and address of the UK responsible person.
+ Cosmetic Product Safety Assessment Report (CPSR): Post 31st December 2020, all Cosmetic Safety Assessments UK will require a signature of a safety assessor in possession of a British university diploma. All CPSRs signed prior to the exit date will remain valid on both sides of the divide regardless of the safety assessor’s qualification.
+ Product Information File (PIF):The PIF must be held by the UK Responsible person and must be kept for a period of ten years after the last batch of the cosmetic product was placed on the market.
+ CPNP Registration UK: All cosmetics products placed on the UK market will have to be notified to the Secretary of the State within 90 days, post Brexit, through an online portal similar to the CPNP. Separate notifications will be required in both the EU and the UK, and all the UK entities on the EU CPNP would be deactivated on the exit day.
Freyr with exclusive offices in the UK and Germany would support re-notification of your product using existing documentation, preparation of Cosmetic Safety Assessments UK signed by both British and Continental-qualified safety assessors, ensure cosmetic formulation and label compliance in UK, compile the Product Information File (PIF) for UK, perform CPNP Registration UK, and act as a Responsible Person on your behalf within the UK and the EU27.