The UK has implemented its own cosmetics regulation. As of January 1st 2021, the UK regulation is very similar to the current EU Cosmetics Regulations. However, references to the EU have been replaced; English is the only language of communication; PIF’s have to be maintained up-to-date and available for the UK authorities in English; the Responsible Person for the UK has to be UK based; and products have to be notified in SCPN (the UK equivalent to the EU CPNP).
First of all, it is important to have PIF for each product complete, up-to-date and in English. The PIF is key input for the safety assessment report (CPSR). English is accepted in several EU member states (like the Netherlands, where we are based), but not in all. TRC provides all its documentation in English as a standard including the safety assessment report, Regulatory Content Briefs and data reports.
Secondly, choose one single service provider as your safety assessor and Responsible Person for both the EU and the UK. Splitting tasks between one or more safety assessors and Responsible Persons for the EU and the UK has many downsides such as:
· Higher costs due to paying for partially overlapping services (a Responsible Person will always require a certain level of review and insurance before taking over responsibilities and liabilities)
· Significant inefficiencies in managing data, documents and expert opinions across multiple service providers
· Longer lead-times from product development through product notification
· Lacking one single entity taking the lead and responsibility to ensure current and future compliance and thereby the success of your products
· A cumbersome and costly process for carrying through product updates (e.g. changing suppliers, reformulations, (re-) assessment, adjustments of labels of claims, renotifications)
The next step, following safety assessment is to ensure that your product artwork and claims are compliant. TRC will provide you with a Regulatory Content Brief that contains all mandatory label information for each product, such as mandatory warnings, use instructions, RP details and of course the INCI ingredients list.
It is possible to work with a single label for both the EU and/or the UK as long as the label includes the mandatory information in the local language(s) of the countries where the product is marketed. The label also needs to include RP details of both the EU and the UK based Responsible Persons. Ensuring label and claim compliance is a much easier task when using one single compliant formula in both the EU and the UK and working with one single service provider.
And finally, make sure that your products are properly notified in the UK and that the PIFs are readily available at all times to the local authorities.
We are aware of the impact and costs to brand-owners, importers, distributors and other stakeholders as a result of 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 all-in RP services including in-house safety assessments through our entities in both 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
· All product updates (e.g. changing suppliers, reformulations, (re-) assessment, adjustments of labels of claims, renotifications) are processed in a matter of days and free of charge
We have a unique offer in place for companies marketing cosmetic products in the UK and/or the EU:
· no upfront one-time costs for PIF review, safety assessment, label and claim review and/or notification
· a customised and competitive offer based on the current regulatory status of your products, and the quality of your data and documents
· short lead-times including EU CPNP and/or UK SCPN 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.