Dr Mojgan Moddaresi, Managing Director of Personal Care Regulatory Ltd, provides their advice regarding Brexit and the beauty industry.
It is nearly Christmas time, and, in terms of Brexit and regulatory landscape, it means that we are reaching to the end of Brexit transition period.
The United Kingdom exited the EU in 2019 and at the end of 2020, the transition period is finalised. But what does it mean for the beauty industry in the UK? What should you do to ensure that you are complying with the correct regulation and your supply chain won’t be affected?
Image credit: Cosmetic Design Asia
Lets’ discuss different scenarios in the supply chain:
If you are a distributor, one example might be running a beauty/hair salon in the UK, you may buy your beauty products directly from an EU based brand. Previously, as one of the distributors in the EU region, you didn’t need to be concerned about custom release or compliance of your products with the EU cosmetic regulation (EU 1223, 2009). But what will be changed by Brexit?
From the 1st January 2021, you will be considered as an importer. Under the UK cosmetic regulation, the importer of cosmetic products can be considered as the responsible person of a cosmetic products, and liable to ensure the FULL legal and safety compliance of products on the market.
Furthermore, as an importer, you are responsible to release the products from UK customs. Currently UK and EU negotiation has still not been finalised. If a trade agreement is reached, there is a possibility of 0% tariffs. Otherwise, the UK and the EU should trade under World Trade Organisation rules, meaning goods exporting from the EU to the UK will be subject to the UK Global Tariffs Plan.
Image credit: Personal Care Regulatory Ltd via YouTube
So, if you are a salon owner, or in the beauty industry selling brands imported from the EU what you should do?
1- Ask the cosmetic brand’s sales team if they have allocated a UK Responsible Person for the products
2- There is a grace period (90 days) after 1st January 2021, to ensure all the cosmetic products are notified on the UK cosmetic portal.
3- If your products are currently available on the market, you will have a 2 years grace period to ensure a UK responsible person’s address is available on the products’ labels.
If you are a UK based brand owner, unfortunately there is no grace period for appointing an EU responsible person for your cosmetic products.
If you don’t want to lose your EU market, you should ensure to appoint an EU responsible person for your products. Your products’ labels should have an EU responsible person’s address after Jan 2021. Furthermore, UK businesses access to the cosmetic portal notification in the EU will be ceased after 1st Jan 2021.
Personal Care Regulatory Ltd., with offices in the UK and the EU, provides extensive end-to-end compliance services, including Responsible Person service, and UK and EU portal notification services.
If you have any questions, or need help to navigate your obligation after Brexit, please drop us a line at: info@personalcareregulatory.eu
Reference: Do you want to know more about who the responsible person can be and what are the responsibilities.
Watch to this video to find out more.
Author: Dr Mojgan Moddaresi (Aka Dr M)
She is a PharmD with a PhD in cosmetic science. She has extensive experience in pharmaceutical, biopharma in quality and formulation roles and extensive experience in the cosmetic industry.
She is managing director of Personal Care Regulatory Ltd, a service company based in Cambridge and Dublin. The company is specialised in tailor made approach for helping SME and start up to launch and grow in different markets (Pain free compliance support).
