How do UK and EU cosmetics regulations differ after Brexit?

Post-Brexit, UK and EU cosmetics regulations are diverging. Key differences include: the UK uses a different default body weight (70kg vs EU's 60kg) for safety calculations, the UK has its own CMR substance assessment (64 substances differ), the UK uses SCPN instead of CPNP for product notification, and the UK Responsible Person must be UK-based. Our tool tracks all 27+ points of divergence.

Do I need separate compliance for UK and EU cosmetics?

Yes. Since Brexit, cosmetic products need separate compliance for the UK and EU markets. This includes separate Responsible Persons (UK-based for UK, EU-based for EU), separate product notifications (SCPN for UK, CPNP for EU), and potentially different formulations if ingredient restrictions diverge. Our UK-EU Divergence tool identifies exactly where your product needs dual compliance.

What is the SCPN for UK cosmetics?

SCPN (Submit Cosmetic Product Notification) is the UK's replacement for the EU's CPNP system. All cosmetic products sold in Great Britain must be notified through SCPN. Northern Ireland follows EU CPNP rules under the Windsor Framework. Products sold in both markets need notification in both systems.

UK vs EU

UK-EU Divergence Tracker

Post-Brexit regulatory differences for cosmetics

Check Any Ingredient

Search our 30K+ ingredient database for real-time UK vs EU regulatory comparison.

Body Weight Default

60 kg

EU Default

70 kg

UK Default

Impact: Different Margin of Safety (MoS) calculations. A product safe at EU 60kg may calculate differently at UK 70kg.

Responsible Person

EU EU RP

Must be established in EU. Notify via CPNP.

UK UK RP

Must be established in UK/NI. Notify via SCPN.

Selling in both markets requires BOTH an EU RP and a UK RP.

UK-Specific CMR Substances

64 New Entries

UK Schedule 2 entries 1680-1743

Placement deadline Apr 20, 2025

Sell-through deadline Oct 20, 2025

Notification Systems

EU CPNP

Cosmetic Products Notification Portal

Portal →

UK SCPN

Submit Cosmetic Product Notification

Portal →

Full Comparison

Aspect	EU EU	UK UK	Impact
Regulation	EC 1223/2009	UK Cosmetics Regulation 2009	Separate legal frameworks
Body Weight	60 kg	70 kg	Different MoS calculations
Notification Portal	CPNP	SCPN	Dual notifications required
Responsible Person	EU-based	UK-based	Two RPs needed for both markets
CMR Substances	EU Annex II	UK Schedule 2 (+64 new)	UK has additional restrictions
56 New Allergens	July 2026/2028	Not adopted yet	Potential future divergence
Microplastics Ban	2027-2035	Under review	UK may follow different timeline
Northern Ireland	Follows EU rules (Windsor Framework)		Special consideration needed

Substance-Specific Divergences

UK Compliance Timeline (2024-2027)

IE Northern Ireland (Windsor Framework)

UK Enforcement Penalties (OPSS)

Offense	England/Wales	Scotland/NI

Practical Guidance

Selling in Both Markets?

Appoint both EU RP and UK RP
Notify on both CPNP and SCPN
Use 60 kg for MoS (stricter)
Comply with UK CMR deadlines
Maintain two PIFs (EU + UK)

Key Actions

1. Review products for 64 UK CMR substances
2. Update safety assessments for 70 kg UK
3. Ensure UK RP arrangements in place
4. Monitor NI special requirements
5. Track future allergen/microplastics divergence
6. If selling in EU+UK: label 82 allergens (EU) while UK still requires only 26 — use EU standard as superset
7. CTPA/IFRA UK recommend single EU-compliant label (82 allergens) for all markets — dual label cost far exceeds savings from shorter UK INCI

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