Cosmetic product safety reports and UK labelling requirements
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Every cosmetic product sold in Great Britain needs a UK-based Responsible Person, a cosmetic product safety report (CPSR) signed by a qualified safety assessor, a notification through the government's Submit Cosmetic Product Notification (SCPN) service, and a label that meets the UK Cosmetics Regulation. All of this has to be in place before the product goes on sale.
For beauty brands, most of the work happens before launch. But labelling, batch codes, expiry dates and storage conditions all matter again once stock moves into a warehouse, because distributors have legal duties too, including storing and transporting products properly.
This guide covers how cosmetic regulations work in the UK, what the Responsible Person does, what goes into a CPSR, how notification works, the UK cosmetic labelling requirements, an important labelling deadline at the end of 2027, and what all of this means when a Third-Party Logistics (3PL) provider handles your stock.
Cosmetic regulations in the UK
In Great Britain, cosmetics are regulated under the UK Cosmetics Regulation: the EU Cosmetics Regulation (EC) No 1223/2009 as it was carried into UK law after Brexit and amended for GB. The Office for Product Safety and Standards (OPSS) publishes statutory guidance on the rules, and local Trading Standards teams enforce them.
Northern Ireland follows the EU Cosmetics Regulation under the Windsor Framework. Products that meet the NI rules can be sold in Great Britain as qualifying Northern Ireland goods, but they still need a UK-based Responsible Person and a notification to the UK service.
What counts as a cosmetic?
A cosmetic is a substance or mixture applied to external parts of the body, such as the skin, hair, nails, lips, teeth or the inside of the mouth, to clean, perfume, change the appearance, protect, keep in good condition or correct body odours. That covers skincare, make-up, perfume, haircare, deodorants, toothpaste, nail products and sun protection.
Products that are swallowed, inhaled, injected or implanted aren't cosmetics. Some products sit on the borderline with medicines, for example where they make medicinal claims. The Medicines and Healthcare products Regulatory Agency (MHRA) can advise on those, and our guide to GDP certification and MHRA licensing covers what changes if a product is classed as a medicine.
The rules apply to any supply in the course of business, including free samples. A sample in a subscription box or a gift with purchase needs to be just as compliant as the full-size product.
The Responsible Person
A cosmetic product can't be placed on the GB market unless there's a Responsible Person (RP) based in the UK. The RP is legally responsible for making sure the product complies with the regulation.
Who the RP is: a UK manufacturer is the RP for products it makes in the UK and sells here. A UK business that imports cosmetics, including from the EU, becomes the RP by default. Manufacturers and importers can appoint a third party in the UK as RP through a written mandate, which the third party must accept in writing.
What the RP does:
Makes sure each product has a safety assessment and a CPSR.
Keeps a Product Information File (PIF) in English for every product, available to the authorities at the address it has notified.
Notifies each product through SCPN before it goes on sale.
Makes sure the labelling is correct.
Takes corrective action, withdraws or recalls products that don't comply.
Reports serious undesirable effects to OPSS.
If you're an overseas brand selling into Great Britain, you'll need a UK RP before your first sale, usually your importer or a specialist RP service.
What is a cosmetic product safety report?
A cosmetic product safety report is the document that shows a product is safe for human health under normal and reasonably foreseeable use. Every cosmetic needs one before it goes on sale, and it forms part of the product's PIF.
The CPSR has two parts:
Part | What it covers |
Part A: safety information | The data behind the assessment: composition, physical and chemical properties and stability, microbial quality, impurities and packaging, normal and foreseeable use, exposure to the product and its ingredients, the toxicological profile of each ingredient, any undesirable effects, and other relevant information |
Part B: safety assessment | The safety assessor's conclusion that the product is safe, or safe with restrictions; any warnings or instructions needed on the label; the reasoning behind the conclusion; and the assessor's name, address, qualifications and signature |
Who can sign it: the safety assessor needs a university-level qualification in pharmacy, toxicology, medicine or a similar discipline, or a course recognised as equivalent.
Extra scrutiny for some products: products intended for children under three, and products for external intimate hygiene, need a specific safety assessment.
Keeping it current: the CPSR should be reviewed when new data could change the conclusion, such as a reformulation, a new supplier for an ingredient or reports of reactions. The PIF must be kept for ten years after the last batch is placed on the market.
Unless you have a qualified assessor in-house, you'll need to commission CPSRs from a specialist safety assessor or a regulatory consultancy. Budget time for stability and microbial testing, because Part A relies on that data.
Notifying your products
Before a product goes on sale in Great Britain, the RP must notify it through the Submit Cosmetic Product Notification service, which replaced the EU's Cosmetic Products Notification Portal (CPNP) for GB.
A notification includes the product's category and name, the RP's name, the address where the PIF is kept, an emergency contact, the frame formulation for medical treatment, any CMR substances (those classed as carcinogenic, mutagenic or toxic for reproduction), the original labelling and a photo of the packaging.
Two timing rules are easy to miss:
Nanomaterials: products containing nanomaterials that aren't colourants, preservatives or UV filters must be notified at least six months before they go on sale.
Changes: if any notified information changes, such as the label or the RP's address, the RP must update the notification straight away.
The information is shared with the National Poisons Information Service, so accurate formulation details matter beyond compliance.
Cosmetic labelling requirements in the UK
UK cosmetic labelling requirements are set out in Article 19 of the UK Cosmetics Regulation. Most information must appear clearly and indelibly on both the container and the outer packaging, in English:
Requirement | What's needed | Notes |
Responsible Person | Name and address of the UK RP | On both container and packaging. See the 2027 deadline below |
Country of origin | The country where an imported product was made | "Made in the EU" isn't accepted |
Nominal content | Weight or volume at the time of packing | Not needed for free samples, packs under 5g or 5ml, or single-use sachets |
Date of minimum durability | "Best used before the end of" or the hourglass symbol, with the date | Needed when a product lasts 30 months or less |
Period after opening (PAO) | The open jar symbol with a number of months, such as 12M | Used instead of a best-before date when a product lasts more than 30 months |
Warnings and precautions | Any warnings required by the regulation or the safety assessor | Can go on an enclosed leaflet if there's no room, with the hand-and-book symbol |
Batch number | A code identifying the manufacturing batch | Outer packaging alone if the container is too small |
Function | What the product does | Only when it isn't obvious from the presentation |
Ingredients | Full list headed "Ingredients", using INCI names in descending order of weight | Can appear on the outer packaging alone |
A few ingredient rules are easy to miss:
Under 1%: ingredients below 1% can be listed in any order after the rest.
Fragrance: perfume compositions are listed as "parfum", but certain fragrance allergens must be named individually above 0.001% in leave-on products and 0.01% in rinse-off products.
Shade ranges: decorative products sold in several shades can list all colourants used across the range after "may contain" or "+/-".
Nanomaterials: add "(nano)" after the ingredient name.
The December 2027 deadline for UK Responsible Person details
Since 2021, products have been allowed to carry EU Responsible Person details instead of UK ones, as a transitional arrangement. That arrangement ends on 31 December 2027. After that date, products placed on the GB market need the UK RP's name and address on the label.
Cosmetics often stay on shelves and in warehouses for months, so start planning label changes now. Check how much stock you hold with EU-only details, and when your next print runs are due.
Claims
Any claim on the label or in marketing, from "hydrating" to "not tested on animals", must be truthful, supported by evidence and not misleading. Cosmetic products can't be sold in GB if they, or their ingredients, have been tested on animals to meet the regulation's requirements.
What cosmetic regulations mean for fulfilment
Most cosmetic compliance work sits with the RP before launch. Once stock is in a warehouse, a few obligations and risks carry straight through to fulfilment.
Distributor checks: distributors must check that the RP's name and address, batch number, ingredient list and English-language information are on the label, and that the best-before date hasn't passed. Build those checks into goods-in so non-compliant stock never reaches a customer.
Storage and transport: distributors have a duty to store and transport products so they stay compliant. If your label carries storage instructions, such as "store below 25°C" or "keep away from sunlight", your 3PL needs to follow them.
Batch and expiry tracking: recalls are issued by batch, so your 3PL's Warehouse Management System (WMS) should record batch numbers at goods-in and dispatch, and pick on a First Expired, First Out (FEFO) basis. Supply chain records need to be kept for three years.
Samples and kits: free samples, minis and gift-with-purchase items must meet the same rules as full-size products. If your 3PL builds kits or subscription boxes, check every component's label before the build.
Relabelling: if stock needs new labels, for example to add UK RP details before the 2027 deadline, agree who approves the artwork, who applies the labels and how the RP updates its notification.
Aerosols and flammables: aerosol cosmetics must also meet aerosol dispenser rules, and perfumes and aerosols can be classed as dangerous goods for storage and transport. Our platform data shows hazardous goods storage is offered by a minority of UK 3PLs, so check this early.
Complaints and reactions: a customer who reports a reaction may be describing a serious undesirable effect. These must be reported to OPSS within 30 calendar days of anyone in the business becoming aware, so complaints that reach your 3PL or customer service team need a fast route to the RP.
Returns: opened or used cosmetics shouldn't go back into sellable stock, and all returned stock needs checking for damage, tampering and expiry before it goes back on the shelf. Our guide to managing returns with a 3PL covers the process.
Northern Ireland and EU stock: if you sell outside Great Britain, keep stock labelled for different markets under separate Stock Keeping Units (SKUs) so the right version reaches each customer.
Questions to ask a cosmetics 3PL
Use these questions alongside our questions for a 3PL discovery call when you compare providers.
Experience: which cosmetics brands do you work with, and which product types do you handle?
Goods-in checks: do you check labels, batch codes and best-before dates when stock arrives, and what happens to stock that fails?
Batch and expiry tracking: do you record batch numbers at goods-in and dispatch, and pick on a FEFO basis?
Recalls: how quickly can you identify and quarantine every unit from a specific batch, and list the customers who received it?
Storage conditions: can you meet the storage instructions on my labels, including temperature limits?
Restricted products: can you store and ship aerosols, perfumes and other flammable products, and which carriers accept them?
Kitting and samples: can you build gift sets, sample packs and subscription boxes, and check every component before the build?
Relabelling: can you apply new labels, for example to add UK RP details before the 2027 deadline, and how do you control the process?
Complaints: how will customer complaints about reactions be passed to us, and how quickly?
Returns: how do you inspect returned cosmetics, and who decides what goes back into stock?
Cosmetic regulations FAQs
What is a cosmetic product safety report?
A CPSR is the safety assessment every cosmetic needs before it goes on sale in Great Britain. Part A sets out the safety information, such as composition, stability, microbial quality and the toxicology of each ingredient. Part B is the qualified safety assessor's conclusion, signed and dated.
Who can write a CPSR?
A safety assessor with a university-level qualification in pharmacy, toxicology, medicine or a similar discipline, or an equivalent recognised course.
What are the cosmetic labelling requirements in the UK?
Labels must show the UK Responsible Person's name and address, the country of origin for imports, the nominal content, a best-before date or period-after-opening symbol, warnings, a batch number, the product's function if it isn't obvious and a full ingredient list using INCI names.
When do UK Responsible Person details have to be on cosmetic labels?
Products can currently carry EU Responsible Person details instead, under a transitional arrangement that ends on 31 December 2027. After that, products placed on the GB market need UK RP details on the label.
Do I need to notify cosmetic products in the UK?
Yes. The Responsible Person must notify each product through the government's SCPN service before it goes on sale in Great Britain. Products containing certain nanomaterials must be notified six months in advance.
Do free samples need to comply with cosmetic regulations?
Yes. Free samples count as supply, so they must meet the same safety, notification and labelling rules as full-size products. Some content labelling exemptions apply to very small packs and single-use sachets.
What are the cosmetic regulations in Northern Ireland?
Northern Ireland follows the EU Cosmetics Regulation under the Windsor Framework. Qualifying Northern Ireland goods can be sold in Great Britain, but they still need a UK-based Responsible Person and a UK notification.
Find a 3PL for your cosmetics brand
Cosmetic compliance starts with a UK Responsible Person, a signed CPSR, an SCPN notification and a compliant label, and continues in the warehouse with label checks, batch tracking and careful storage. Compare cosmetics fulfilment providers on fulfilment.com and get quotes from 3PLs that already handle beauty brands.
