Britain is not the EU — notify now, relabel by 2027
A finished CPNP notification does not get a Korean brand into Britain, and the first shipment is where that becomes clear. Great Britain runs its own notification service and insists the responsible person sit at a UK address, yet the deadline for printing that address on the pack has moved to 31 December 2027.
Great Britain does not recognise an EU CPNP notification. A responsible person established at a UK address has to notify separately through SCPN, a service that had taken 861,686 notifications from 24,112 registered responsible persons as of 28 May 2026. The obligation to print that UK address on the pack, however, sits under a transitional period now extended to seven years, running to 31 December 2027.
The notification goes somewhere else
Selling in Britain means notifying Britain. A CPNP record does not travel across the Channel, and Great Britain — England, Scotland and Wales — runs its own service, Submit Cosmetic Product Notifications. Opened in December 2020, it had received 861,686 notifications from 24,112 registered responsible persons as of 28 May 2026.
The responsible person must be established at a UK address. That role can sit with the manufacturer, the importer, a distributor selling under its own brand, or a company or individual appointed by the manufacturer or importer. Government guidance states plainly that mail forwarding services and PO box addresses do not qualify, which is the first thing worth checking when comparing agency quotes.
A notification carries the product category and name, the responsible person's name, where the product information file is kept, a named contact for urgent enquiries, details of any nanomaterials and CMR substances, the chemical and ingredient summary, and images of the label and packaging. Search access to what has been filed is limited to competent authorities and the National Poisons Information Service, so the database is no use for looking at what a competitor has submitted.
The label waits until 31 December 2027
Notify now, relabel later. That order is often reversed in practice, which is how brands spend on print plates earlier than they needed to. The requirement to show the UK responsible person's name and address on the pack sits under a transitional provision, and an amending instrument made on 21 December 2022 replaced the period of 36 months with seven years. Counted from 31 December 2020, the relief runs out on 31 December 2027.
Until then a label built to Article 19(1)(a) of the EU Cosmetic Products Regulation — the EU responsible person's name and address, plus country of origin — remains acceptable in Great Britain. That is the full extent of the relief. Notification duties and ingredient restrictions were never covered, so SCPN has to be complete before the first shipment even where nothing on the artwork changes.
| Item | Great Britain | Northern Ireland | EU |
|---|---|---|---|
| Notification service | SCPN | CPNP | CPNP |
| Responsible person established in | UK | Northern Ireland or EU | EU |
| RP address on label | EU address accepted to 31 Dec 2027 | Per EU regulation | Per EU regulation |
| PIF language and retention | English, 10 years after last batch | Per EU regulation | Per EU regulation |
Timing the plate change is worth a calculation of its own. Printing a GB-specific label now means running two versions in parallel for two years, while leaving it to the end of 2027 puts a whole year's production on one deadline. Fast-turning lines can wait; artwork printed once and used for years is cheaper to update at the next revision, with the UK address added then.
UKCA is not a cosmetics mark
If a quote carries a line for UKCA certification, ask what it covers. Cosmetic products bear no conformity marking. UK cosmetics compliance runs on the responsible person, the notification, the product information file and the cosmetic product safety report, whose Part B is signed by an assessor holding a degree in pharmacy, toxicology, medicine or a comparable field.
Where a mark does appear is aerosols. Spray sun care, hair mist and anything else in a dispenser falls under the aerosol dispensers regime, and an amending instrument in force from 1 October 2024 removed the time limit on using the inverted epsilon. Either the inverted epsilon or UKCA is therefore acceptable, with no cut-off to plan around.
From 2026 the annexes run on different dates
This year's calendar shows how little the UK now follows EU amendments automatically. The EU adopted Regulation (EU) 2026/78 on 12 January 2026 and applied it in one step from 1 May. Britain carried the equivalent changes across in SI 2026/23, split the coming-into-force dates in two, and added separate sell-through periods.
| UK change | In force | Stock placed before that date sellable until |
|---|---|---|
| 3-(4'-methylbenzylidene)camphor prohibited, removed from Annex VI | 2026-07-15 | 2027-01-14 |
| Newly classified CMR substances prohibited, acetone oxime among them | 2026-08-15 | 2027-02-14 |
| Formaldehyde-releaser warning threshold cut from 0.05% to 0.001% | 2026-07-15 | — |
A UV filter leaving Annex VI means reformulation, not relabelling. Stock placed on the market before the prohibition can be sold until 14 January 2027, which puts GB and EU inventory on different run-down clocks for the same SKU. The warning threshold dropping from 0.05% to 0.001% brings artwork work with it.
Selling across the UK is two notifications
A contract written for UK-wide distribution asks for two notifications. Northern Ireland continues under the EU Cosmetic Products Regulation, so the responsible person there has to be established in Northern Ireland or the EU and notification goes through CPNP. If a quote treated the UK as one territory, it is worth asking how many responsible persons it assumed.
Nanomaterials stretch the timeline. Article 16(3)(c) requires electronic notification at least six months before the product is placed on the market, and the notification goes to the Secretary of State. A new colourant, UV filter or preservative follows a different route again, with a safety dossier submitted to OPSS. Fixing a launch date first and fitting the paperwork around it is how half a year disappears.
In short
- Notify separately through SCPN. The responsible person needs a real UK address; a PO box will not do.
- The UK address on the pack is deferred to 31 December 2027. Notification and ingredient rules are not deferred at all.
- Cosmetics carry no UKCA mark. Only aerosols touch marking, and the inverted epsilon still works.
- UK-wide means SCPN plus CPNP. Nanomaterials add a notification six months ahead.
Which ingredients are moving right now is on today's ingredient signal, and category price bands and cost structure sit in the product planner.
*Sources: GOV.UK, Submit a cosmetic product notification / GOV.UK, Making cosmetic products available to consumers in Great Britain / GOV.UK, New data on UK cosmetic product safety notifications, published 17 July 2026 — 861,686 notifications from 24,112 responsible persons as of 28 May 2026 / The Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393, made 21 December 2022), regulation 3 — "36 months" replaced with "seven years" / CTPA, UK Government Confirms Further Extensions to Marking Requirements / Biorius, UK Responsible Person — 31 December 2027 / Regulation (EC) No 1223/2009 as retained, Article 16(3) — six-month nanomaterial notification / Mishcon de Reya, UK and EU Cosmetics Regulations: 2026 updates — SI 2026/23 and Regulation (EU) 2026/78 dates / ChemLinked, New UK Regulation Grants Flexibility in Conformity Marking for Aerosols — in force 1 October 2024*
Questions people ask
No. Great Britain has its own service, Submit Cosmetic Product Notifications, and the responsible person must be established in the UK. Government guidance rules out mail forwarding services and PO box addresses, so check that an agent has real premises.
Not until 31 December 2027. A label meeting Article 19(1)(a) of the EU Cosmetic Products Regulation still passes, because an amending instrument made on 21 December 2022 replaced the transitional period of 36 months with seven years. The relief covers only the responsible person's details and country of origin, so notification and ingredient compliance still have to be right before the first shipment.
Cosmetic products carry no conformity marking at all. The mark arises only under the aerosol dispensers regime, where since 1 October 2024 either the inverted epsilon or UKCA may be used with no end date. If a quote carries a UKCA certification line, ask what it is actually for.
Two. Great Britain needs SCPN with a UK-established responsible person, while Northern Ireland continues under the EU regulation and needs a responsible person in Northern Ireland or the EU plus a CPNP notification.
The product information file and safety report largely carry over, but the file is kept in English and held for ten years after the last batch was made available. The annexes have begun to diverge: the UK split its 2026 ingredient changes across 15 July and 15 August.