REGULATORY & COMPLIANCE based in the EU27 then had to put a RP in place in the UK and viceversa . The obligations to give the name and address of the RP and the product ’ s country of origin , for imported products , are still in a grace period of two years . After the end of 2022 , products that fail to show this must be withdrawn . The UK ’ s product notification portal , Submit Cosmetic Product Notification ( SCPN ), has come into place as the UK equivalent of the EU Cosmetic Product Notification Portal . The requirement to notify products placed on the market from 1 January 2021 came into effect on that date ; a threemonth grace period was allowed for products already on the UK market before that to have their notifications updated . The OPSS is continually reviewing the SCPN and updating its IT capabilities . Schedule 13 of the SI laid down provisions for the new UKCA mark to replace the EU ‘ reverse epsilon ’ CE mark under UK Aerosols Regulations Amendment No . 7 . This applied to all aerosols and represented a departure from existing obligations under EU rules . The British Aerosols Manufacturers Association and CTPA had discussions with the OPSS about this . OPSS has now extended the implementation periods . It is now the case that aerosols sold in GB can carry either the ‘ reverse epsilon ’ or the UKCA mark until 31 December 2022 , instead of 31 December 2021 , as originally envisaged . Thereafter , they must carry the UKCA mark , which can be applied as a sticker until 31 December 2023 . In NI , the reverse epsilon will apply .
UK chemicals management
The EU CPR has a series of annexes that control certain ingredients , including banned and restricted substances , preservatives , colours and UV filters . These annexes were all retained in the UK Cosmetics Regulation . Annexes to the CPR are reviewed regularly , ingredients are always under scrutiny and updates are made , which means that the EU and the UK will inevitably diverge over time . The OPSS has set up a new group , the Scientific Advisory Group on Chemical Safety in Consumer Products ( SAG-CS ), which is the equivalent of the EU Scientific Committee on Consumer Safety ( SCCS ). It is chaired by Professor Shirley Price of the University of Surrey and members include Professor Mohammed Qasim Chaudhry of the University of Chester , a past chair of SCCS . The process of ingredient management in GB mirrors that in the EU . If an issue is raised , the OPSS will engage with industry and then is likely to ask SAG-CS to review any data that industry provides . It is anticipated that SAG-CS will come up with an opinion , prior to any legislative process . Exactly how that process will work remains to be seen and the CTPA is in contact with the OPSS regularly for clarification . ( The CTPA has also worked with the OPSS to set up a Cosmetic Stakeholders Group , equivalent to the EC ’ s Cosmetic Working Group , which meets three times a year to look at SCCS opinions . A chair has been appointed and the group is intending to meet before the end of the year .) SAG-CS currently meets six times per year . Its remit is not only for cosmetics ; it is also responsible for independent review of any ingredient issues in toys and textiles . Indeed , all of the mandates remitted to it so far have concerned toys and there is still a degree of uncertainty over how it will work in practice as regards cosmetics . Some ingredients for which updates to the EU CPR were published before 1 January 2021 – notably HEMA and di-HEMA for artificial nails , UV filter S87 and various hair dye amendments - have been included in the UK Cosmetics Regulation . Others that have been published since that date are subject to restrictions under the CPR but have not been included in the annexes of the UK Cosmetics Regulation and are likely to require review by SAG-CS .
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EU Cosmetic Products Regulation UK Cosmetics Regulation
• Responsible Person
• Product Information File
• Safety Assessment
• Labelling
• Cosmetic product definition
• Claims self-regulation
• Notification Portal ( CPNP )
• Cosmetovigilance
• Ingredients monitoring and restrictions
• Responsible Person
• Product Information File
• Safety Assessment
• Labelling
• Cosmetic product definition
• Claims self-regulation
• Notification Portal ( SCPN )
• Cosmetovigilance
• Ingredients monitoring and restrictions
Figure 1 – Retention of EU law into UK law
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