In the event of hard BREXIT, the United Kingdom will effectively become a third country from 29th March 2019.
As a result, cosmetic companies won’t benefit from a transition period and will have to be fully compliant with new provisions at that time.
If the European Commission and the British Parliament seek an agreement, a transition period will potentially be granted.
The cosmetic industry will therefore benefit from an additional year and 9 months (December 31st, 2020) to comply with the new provisions post-BREXIT.
WHAT DOES IT IMPLY ?
UK Responsible Person
A Responsible Person in the UK will be mandatory to sell cosmetic products in the country. A cosmetic brand selling both in the EU and in the UK will then need a Responsible Person specific to each territory.
The name of the UK RP will have to be added to the CPSR. An update of the Product Information File (PIF) is therefore needed for cosmetic products sold in the UK.
Responsible Person’s contact details
In case of selling in the UK, the UK Responsible Person’s contact details will have to feature on the product label.
EU and UK Responsible Persons’ information will therefore have to appear on the label if the product is sold in both territories.
According to the EU regulations, the manufacturing country has to figure on the product label if this country is outside EU.
- If you are manufacturing in the UK and selling in the EU, the mention “made in UK” will have to be added on your label.
- If you are manufacturing in the EU and selling in the UK, the mention “made in EU” will have to be added on your label.
Each product will have to be notified on the UK notification system within 90 days following the Brexit day.
The notification portal will be available on January 1st, 2021.
A product sold on both markets will then need to be notified on the UK notification system and on the CPNP.