The UK has published the draft Cosmetics Regulations that will be implemented post-Brexit. Initial regulations will be very similar to the current EU Cosmetics Regulations but: references to the EU will be replaced; English will be the only language of communication; PIF’s will have to be maintained and available for the UK authorities; Responsible Persons in the UK will have to be UK based; and products will have to be notified in a UK portal equivalent to the EU CPNP.
In all scenario’s ranging from a deal to a no-deal Brexit, it is expected that a reasonable amount of time will be allowed for UK product notification and label/artwork adjustments. Thereby excluding in market enforcement by the UK authorities as from day one.
Several things can be done to best prepare under the current circumstances. First of all it is important to have your PIFs and EU CPNP product notifications up-to-date and compliant with current EU regulations. Once the Brexit date comes closer the product notifications need to be mirrored in the UK “CPNP”. The exact technical data and document transfer possibilities are unclear present day. It is important to have all PIF and CPSR documentation available in the English language for the UK market.
When marketing products both in the EU as well as the UK it is highly recommendable to have your EU RP address in an EU member state where the local authorities accept PIF and CPSR documentation in English, such as The Netherlands or Ireland. TRC provides all its documentation in English as a standard including the safety assessment report (CPSR), cosmetovigilance reports, product claim substantiation and other documents relevant to you and local authorities in The Netherlands and the UK.
Post Brexit, the artwork/labelling needs to include the UK RP details for products marketed in the UK. To avoid last-minute re-labelling efforts and costs, it is a good option to already work with two sets of RP details on your product labels for both the EU and the UK. Do note that product labels need to include the mandatory label information in the local language(s) of the country where the product is marketed as well.
We are aware of the impact and costs to brand-owners, importers, distributors and other stakeholders to prepare for Brexit. Brand-owners and importers must ensure the role of Responsible Person to be fulfilled both in the EU and the UK either by themselves or by contracting and mandating a service provider.
· We provide both through our entities in The Netherlands and the UK
· We do so very effectively and efficiently as we manage all data, documents and reports in our high-quality co-developed software in English
· All information is available cloud-based, in real-time and 24/7 for both the EU and the UK
We have a unique offer in place for companies located in the UK and/or in the EU that are marketing cosmetic products in the UK and/or the EU:
· no upfront one-time costs
· customised and competitive offer based on the current regulatory status of your products and your data and documents
· short lead-times including EU CPNP notification in a matter of weeks rather than months
We can guarantee short lead-times under normal conditions and provided that all information and required testing results are available. Feel free to contact us any time to discuss your context, needs, timelines and how we can help.