Selling cosmetics in the UK and the EU: a guide for US beauty brands

If you sell cosmetics in the US, MoCRA has already taught you the routine: register your facilities with the FDA, list your products, keep safety records and report serious adverse events. The UK and the EU have run a stricter version of that system for years, and one rule sets it apart: before a product goes on sale, someone established locally must take legal responsibility for it.

Since Brexit, there are also two systems to satisfy, not one. Here is what a US beauty brand needs in place before its first UK or EU order ships.

Two markets, two systems

The EU regulates cosmetics under Regulation (EC) No 1223/2009. It applies in every EU country and, under the Windsor Framework, in Northern Ireland. Great Britain kept its own version of the same regulation, enforced by the Office for Product Safety and Standards (OPSS).

The structure is the same, so most of your work counts twice. The registrations do not.

The Responsible Person

In both markets, a cosmetic product cannot be placed on the market unless a Responsible Person (RP) is established there. If you import, the importer is the RP by default. A US brand without its own UK or EU company appoints a third party by written mandate.

The RP is not a mailbox. They must make sure the product has a safety assessment, keep the product information file, notify the product, check labels and claims, report serious undesirable effects and cooperate with the authorities. Their name and address go on your packaging.

In practice, you need an RP who qualifies for Great Britain (established in the UK) and one who qualifies for the EU (established in the EU or Northern Ireland). A serious RP reviews your file before signing the mandate, so plan for that time.

Four things to finish before the first sale

1. A Cosmetic Product Safety Report (CPSR). Every product needs a safety assessment, signed by a qualified safety assessor with a formal qualification in a field like pharmacy, toxicology or medicine. Your US safety data is useful input, but it has to be rebuilt into the format the regulation requires.

2. A Product Information File (PIF). The PIF holds the product description, the CPSR, the method of manufacture and a statement of compliance with good manufacturing practice, proof of any claimed effect, and data on animal testing. It must be kept at the RP's address for ten years after the last batch is placed on the market. In Great Britain, it must be in English.

3. A product notification. In the EU, the RP notifies each product through the Cosmetic Products Notification Portal (CPNP) before it goes on sale. It is free, and one notification covers every EU country. In Great Britain, the RP notifies through the Submit Cosmetic Product Notifications (SCPN) service before the product reaches the GB market. A CPNP notification does not count in Great Britain, and an SCPN notification does not count in the EU.

4. A compliant label. See the next section.

What changes on the label

Your US label will not work as it is. In both markets, the container and the outer packaging must show:

• the RP's name and address;
• the country of origin for imported products ("Made in USA"; "Made in the EU" is not accepted in Great Britain);
• the nominal content;
• a date of minimum durability, or a period-after-opening symbol for products that last longer than 30 months;
• precautions for use and any mandatory warnings;
• a batch number;
• the product's function, unless it is obvious from the presentation;
• the full ingredient list, using INCI names, in descending order of weight.

Two practical points:

• One pack, two addresses. Until 31 December 2027, Great Britain accepts EU or EEA RP details on the label, though you still need a UK RP. Many brands print both addresses now, so one pack works in both markets after 2027 too.
• Languages. Great Britain requires English. In the EU, each country sets its own language requirements, so a pan-EU pack usually means multilingual packaging or local stickers.

Most cosmetics also fall under product safety rules for online listings. Our GPSR guide for US brands explains what your store and marketplace listings must show.

Products that change category at the border

Some products that are drugs in the US are cosmetics in the UK and the EU. Sunscreens and antiperspirants are the usual examples: in the US they are over-the-counter drugs, while in the UK and the EU they are cosmetics.

Your FDA drug file does not transfer. The product needs a full cosmetics file, and every UV filter must be on the approved list in the market where you sell. The reverse also happens: a product that claims to treat or prevent a disease can be classed as a medicine in the UK and the EU, with a completely different approval route.

Ingredients: check each market separately

The UK and the EU ban and restrict ingredients on separate timetables, and the gap matters.

TPO, a photoinitiator used in gel nail products, shows how. The EU banned it from 1 September 2025, with no sell-through period: products had to come off the shelves on that date. Great Britain followed with its own ban, applying to products placed on the market from 15 August 2026, with existing stock allowed on shelves until February 2027. The EU's next set of restrictions on CMR substances (substances that can cause cancer, genetic damage or harm to reproduction) applied from 1 May 2026.

The lesson: a formula that is compliant in one market is not automatically compliant in the other. Check it against both lists before each production run, not only at launch.

Claims and animal testing

Product claims in the UK and the EU must meet six common criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. Every claim, stated or implied, needs adequate and verifiable evidence, and a cosmetic cannot claim to treat a medical condition.

Animal testing for cosmetics is banned in the UK and the EU, wherever the testing took place. A "not tested on animals" claim is only allowed if no animal tests were carried out or commissioned on the finished product or its ingredients.

Claims are where US marketing copy most often breaks. Our guide to what US online stores get wrong in the UK and the EU covers claims alongside prices, returns and payments.

After launch

• Serious undesirable effects. In Great Britain, the RP or distributor reports them to OPSS within 30 calendar days of the business becoming aware. In the EU, the RP reports them without delay to the authority in the country where the effect occurred.
• Keep the file current. A formula change, a new size or a new claim can mean an updated safety report, PIF and notification.
• Customer complaints about reactions need a route to your RP, in the customer's language. Multilingual customer support that knows your products makes this manageable.

A checklist before your first UK or EU order

• Appoint an RP for Great Britain and one for the EU, each with a written mandate
• Get a CPSR for every product from a qualified safety assessor
• Build a PIF for every product, kept for ten years after the last batch
• Notify each product on SCPN for Great Britain and on CPNP for the EU
• Update labels: RP details, country of origin, durability, batch, INCI list, languages
• Check sunscreens, antiperspirants and other drug-cosmetic borderline products
• Check every formula against both the UK and the EU ingredient lists
• Review claims, including "cruelty-free" and "clean"
• Set up a route for adverse reactions from customers to your RP

Planning to hold stock in a UK or EU warehouse as well? Read do US brands need a UK or EU company?

We have registered over 100 cosmetic products for the UK and the EU, and with our licensed partners we act as Responsible Person for cosmetics in both markets. See Compliance.

Questions

Do I need a Responsible Person if I only sell on Amazon UK or Amazon in the EU?

Yes. The marketplace is not your Responsible Person. Each product needs an RP established in the market where it is sold, named on the label.

Is a CPNP notification valid in the UK?

Only in Northern Ireland. For Great Britain (England, Scotland and Wales), you notify separately through SCPN.

Does my FDA registration and product listing under MoCRA count in the UK or the EU?

No. MoCRA covers the US market only. Your US safety records help with the safety assessment, but the UK and the EU need their own RP, safety report, file and notification.

Can one company be our Responsible Person for both the UK and the EU?

Only if it is established where each market requires: in the UK for Great Britain, and in the EU or Northern Ireland for the EU. Some providers cover both through an entity on each side.

This article is general information, not legal or tax advice. Rules change; check the current position before acting.

Sources

• European Commission: EUR-Lex, Regulation (EC) No 1223/2009 on cosmetic products
• European Commission: Cosmetic Products Notification Portal (CPNP)
• GOV.UK: Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013, Great Britain
• GOV.UK: Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013, Northern Ireland
• GOV.UK: Submit a cosmetic product notification
• EUR-Lex: Regulation (EU) No 655/2013, common criteria for cosmetic claims
• EUR-Lex: Regulation (EU) 2025/877 (Omnibus VII, CMR substances)
• EUR-Lex: Regulation (EU) 2026/78 (Omnibus VIII, CMR substances)
• HPRA (Ireland): TPO added to the EU list of prohibited ingredients
• CTPA: ban of TPO gel nail ingredient in the EU and GB
• FDA: Modernization of Cosmetics Regulation Act of 2022 (MoCRA)