It is a strategic decision to market a product as a cosmetic or as a biocide. For cosmetic products compliance and market access can be achieved short term and at limited costs. However, these cannot have a primary biocidal claim and additional requirements apply. Once notified, cosmetic products can be marketed on the entire EU market, while ethanol-based biocides have to be authorised in each EU member state.
Food supplements claiming to be organic need to comply with Regulation (EU) 848/2018 on a number of aspects. To claim cosmetic products to be organic or natural it is best to follow to follow ISO 16128-2:2017.
The Brexit transition period is likely to end by December 31st 2020. There will be considerable impact. It is important to timely prepare and provide reassurance to importers and retailers in both the UK and the EU.