UK cosmetic product notification is handled through the UK Cosmetic Products Notification Portal (CPNP equivalent) which replaced the EU system after Brexit. All cosmetic products must be notified before they are placed on the market, and a responsible person based in the UK must be appointed to ensure compliance with safety and labelling rules.
This guide explains the core requirements for early-stage founders and e-commerce sellers, focusing on practical steps for product notification, choosing a responsible person, meeting labelling standards and understanding ingredient restrictions so you can sell beauty products legally in the UK.
Understanding the UK Cosmetic Products Notification Portal
The UK operates its own notification system for cosmetic products. Before selling any cosmetic item such as skincare, makeup, haircare or bath products, the product information file and composition details must be submitted to the UK Cosmetic Products Notification Portal. This process confirms that the product has been safety assessed and meets current regulations.
Notification must be completed by the responsible person before the product is first placed on the market. If you import finished goods from overseas suppliers, the UK importer or a designated UK responsible person usually handles this step. Changes to formulation, packaging or claims may require a new notification. Always keep records of the exact product version that was notified.
Practical tip: create a spreadsheet listing every SKU, its notified reference number, responsible person contact details and the date of notification. This helps during platform audits or customs checks when importing.
Appointing a Responsible Person
UK rules require every cosmetic product to have a designated responsible person established in the United Kingdom. This can be the manufacturer, the brand owner, the importer or a third-party service provider. The responsible person ensures the product safety report is current, the product information file is maintained and any serious undesirable effects are reported to the Office for Product Safety and Standards.
Many early-stage founders begin by acting as their own responsible person if they are UK-based and have the technical competence. Others contract specialist consultants or use fulfilment partners who offer responsible person services. Overseas manufacturers cannot act as the UK responsible person.
Reasoning example: if you source private-label creams from a Chinese factory and sell them under your brand via your Shopify store, you or a UK agent must take on the responsible person role. Failing to appoint one means the products cannot legally be sold in the UK.
Steps to choose: list the tasks (safety assessment, notification, labelling checks, record keeping), assess whether your team has the expertise, then decide whether to handle internally or outsource. Document the appointment in writing and keep the agreement available for inspection.
Product Safety Assessment and the Product Information File
Before notification, a qualified safety assessor must produce a Cosmetic Product Safety Report (CPSR) based on the full formulation, raw material data and intended use. The report considers toxicological profiles, exposure levels, stability and microbiological quality. Only after this assessment can the responsible person sign the safety statement.
The Product Information File (PIF) must contain the CPSR, the notified product details, labelling artwork, proof of claims, supplier certificates and any undesirable effect reports. This file must be kept for ten years after the last batch is placed on the market and be available to authorities within a short time if requested.
Practical step: when requesting samples from suppliers, always ask for the full ingredient list with INCI names, batch-specific certificates of analysis and safety data sheets. Use these to brief your safety assessor. Budget time for the assessment process as it can take several weeks depending on complexity and assessor workload.
Labelling Requirements for Beauty Products
UK cosmetic labels must include the name and address of the responsible person, the nominal content (weight or volume), the date of minimum durability (use-by or PAO symbol), batch code, function of the product where this is not obvious, and full ingredients listed in descending order of weight using INCI nomenclature.
Precautions and warnings must appear clearly, for example “avoid contact with eyes” on shampoos or “contains nut oils” where relevant. Claims must be truthful and capable of substantiation; avoid medical-sounding statements on cosmetic products.
Examples of common errors: missing the responsible person postcode, using common names instead of INCI for ingredients, placing the ingredients list on a separate leaflet without a “see leaflet” reference on the container, or omitting the PAO symbol (open jar with number of months) when there is no fixed expiry.
Step-by-step check: draft the label in design software, list every required element, cross-reference against the notified formulation, have the responsible person review, then print a physical sample and photograph it for the PIF before ordering full production.
Ingredient Restrictions and Prohibited Substances
Certain substances are banned or restricted in cosmetic products. These include specific colourants, preservatives, UV filters and fragrance allergens that must be declared on the label if they exceed set thresholds. Annexes to the regulations list permitted and prohibited ingredients; these lists are updated periodically.
Common areas that trip up new sellers are fragrance oils containing undeclared allergens, essential oils used at high concentrations, or colour additives not on the approved list for the intended use (for example rinse-off versus leave-on products). Nano materials and certain plant extracts also have specific rules.
Reasoning example: a founder creating a “natural” face oil with high levels of citrus essential oil must ensure the psoralen content stays within limits and that any phototoxic risk is assessed and labelled if necessary. Always supply the exact formulation to the safety assessor rather than a generic description.
Practical action: when sourcing from overseas suppliers request the full breakdown of any fragrance or essential oil blends. Compare the ingredients against the latest published restrictions. If in doubt, ask the supplier for their EU or UK compliance statement and verify it independently.
Importing Cosmetics and Working with Suppliers
When importing finished cosmetics or components you must ensure the overseas supplier has manufactured to UK standards. Request evidence of their good manufacturing practice, safety data and ingredient compliance. Samples should be tested for microbial contamination and heavy metals where appropriate.
Minimum order quantities (MOQs) from manufacturers often start at 500–2000 units for private label; negotiate smaller test runs where possible. Quality control includes checking that labelling on imported stock matches the notified version exactly. Any deviation requires a new notification.
Customs classification under the correct commodity codes and ensuring the responsible person is identified on commercial invoices helps avoid delays. Keep records of all import documentation for the PIF.
Steps for first import: choose three potential suppliers, request samples and full documentation, appoint or confirm your responsible person, have the safety assessment completed on the final formulation, notify via the portal, then place the order and arrange third-party inspection if the value justifies the cost.
Ongoing Compliance and Record Keeping
Regulations change and new restrictions can be introduced. Responsible persons should monitor official sources for updates. Serious undesirable effects must be reported promptly. Customer complaints that suggest a safety issue need investigation and possible notification.
Maintain version-controlled digital folders for each product containing the current PIF, notified confirmation, label artwork, supplier agreements and safety reports. Review the file annually or when any change occurs.
Many new founders underestimate the administrative workload. Building a simple compliance checklist that covers notification status, label approval, supplier certificates and assessor contact details reduces risk when scaling.
Frequently asked questions
Can I act as my own responsible person for cosmetic products in the UK?
Yes if you are established in the UK and have the necessary competence or access to a qualified safety assessor. Many early founders start this way. You must understand the obligations to maintain the product information file, report serious adverse events and ensure labelling meets legal standards. If unsure, specialist consultants can carry out the role on your behalf.
What is the difference between the UK and EU cosmetic notification systems?
After leaving the EU the UK created its own portal separate from the EU CPNP. Products intended for the UK market must be notified through the UK system with a UK responsible person. Selling in both markets usually requires dual notification and possibly different labelling to show the correct responsible person address in each territory.
Do I need to notify every variation of a cosmetic product?
Notification is product-specific. Different colours, fragrances or significant packaging changes generally require separate notifications. Minor variations such as pack size may not if the formulation, labelling and intended use remain identical. Check with your responsible person to confirm when a new submission is needed.
How do I know if an ingredient is allowed in my cosmetic product?
The UK regulations contain lists of prohibited substances, restricted ingredients and permitted colourants and preservatives. Your safety assessor reviews the full formulation against these annexes. Always provide the exact percentages and supplier specifications rather than generic descriptions to avoid compliance gaps.
What labelling mistakes are most common for new beauty brands?
Frequent errors include missing the responsible person’s full UK address, using non-INCI ingredient names, omitting required warnings, incorrect order of ingredients, and making claims that go beyond cosmetic definitions. Reviewing labels against an official checklist before printing reduces expensive reprinting later.
Related reading: Importing electronics to UK: compliance and certification, Textile and clothing labelling requirements in the UK, Sourcing and selling food supplements legally in UK. Browse all product sourcing guides or apply to Loomworks.