Selling Cosmetics Into the EU and UK After Brexit

A lot of brands that were notifying once for "Europe" before Brexit are still surprised to learn that one filing doesn't cover both markets anymore. The UK and the EU split into two separate cosmetic regimes, each with its own portal, its own Responsible Person requirement, and its own product file. If you sell into both, you're running two compliance tracks side by side, not one track with a wider reach.

Two regimes, two Responsible Persons

Under EU Regulation (EC) No 1223/2009, every cosmetic product placed on the EU market needs a Responsible Person established in the EU. That person or company holds the Product Information File, keeps the Cosmetic Product Safety Report on file, and is who regulators contact if something goes wrong. Since the UK left the EU single market, a Responsible Person based in, say, Ireland or France no longer automatically covers UK sales, and a UK-based Responsible Person no longer covers EU sales.

Practically, this means:

• A brand selling into France, Germany, and the UK needs an EU Responsible Person and a UK Responsible Person. These can be two different companies, or the same company with a presence in both territories, but the legal role has to exist separately in each place.
• Each Responsible Person keeps their own PIF and CPSR for the products they're responsible for. They don't share one file across borders even if the formula is identical.
• If your EU Responsible Person is a distributor or a compliance service in, say, the Netherlands, and you don't have separate UK representation, your UK sales are technically unrepresented, even if the product itself is compliant.

Notification is separate too

On the EU side, products are notified through the CPNP, the Cosmetic Products Notification Portal. On the UK side, notification runs through OPSS via the Submit Cosmetic Product Notification service, usually shortened to SCPN. These are different systems with different logins, different required fields, and no automatic sync between them. Notifying in CPNP does not create a UK record, and notifying in SCPN does not create an EU one.

For a brand already selling in both places, that typically means:

1. Confirm who your EU Responsible Person is and get the CPNP notification filed or transferred to them.
2. Confirm who your UK Responsible Person is, separately, and get the SCPN notification filed under them.
3. Keep both the PIF and the CPSR available on each side, even if it's the same formula. Regulators expect the file to be reachable through their own Responsible Person, not through an intermediary in the other jurisdiction.

What changes if you're a small EU-based brand new to the UK

If you formulate in, say, Spain and have only ever sold in the EU, expanding into the UK isn't just a shipping question. You need a UK-based (or UK-established) Responsible Person before you can lawfully place the product on the UK market, and that person needs to file through SCPN. Some brands handle this by appointing a UK distributor as Responsible Person, others use a compliance service that offers UK representation as a standalone service. Either way, it's a real appointment with real recordkeeping duties, not a checkbox.

The reverse applies too. A UK brand selling into the EU for the first time needs an EU-established Responsible Person, and CPNP notification, even if the product has been on UK shelves for years under SCPN.

Formula changes still need updates on both sides

If you tweak a preservative system or swap a fragrance, both notifications need updating, not just one. It's easy to update the EU record and forget the UK one still references the old formula, especially if different people or teams handle each side. A short internal checklist that ties every reformulation to "update CPNP" and "update SCPN" as two distinct line items saves a lot of confusion later.

A quick reference

Market	Notification system	Responsible Person required	Product file
EU	CPNP	Yes, EU-established	PIF + CPSR
UK	SCPN (via OPSS)	Yes, UK-established	Equivalent product safety file

Neither party has been eliminated by Brexit, they've just been doubled. If your brand only budgeted time and cost for one European filing process, it's worth revisiting that plan before your next launch touches both markets. Cosmetic Comply is building out non-Canada market support, including this kind of dual-market mapping, so if you're tracking two Responsible Persons by hand right now, it's a problem worth watching for tooling that catches up.