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What companies should expect post- transition period

Prepare for after the transition period- Cosmetics Regulation- Responsible Person- CPNP

The transition period ends on 31 December 2020. From 1 January 2021, the European Union (EU) Cosmetics Regulation will be replaced in Great Britain by retained EU law – the GB Cosmetics Regulation.

Businesses based in Great Britain (England, Scotland and Wales) that place cosmetics and personal care products on the GB market will have to comply with the GB Cosmetics Regulation.

Things we know now

Northern Ireland Protocol- At the end of the transition period, the Northern Ireland Protocol will take effect. The Protocol is a practical solution to avoid a hard border with Ireland whilst ensuring the UK, including Northern Ireland, leaves the EU, enabling the entire UK to benefit from future Free Trade Agreements. NI will still have access to the EU market after the transition period. Companies established in NI comply with EU Cosmetics Regulation . Similarly, a chemical substance or a mixture produced in NI and shipped to the EU will not be classified as an ‘imported product’. However, products shipped from GB to NI will have to follow the relevant import Regulation.

What will be the same from January 2021?

The new UK legislation will replace the existing EU Regulation within the UK. This will initially be closely aligned with the EU text with amendments to ensure the new regulation fits its new environment.

Product Information File ( PIF)- The requirements for compiling PIF and the its contents remain the same. In the UK, an up to date Product Information File (PIF) must be maintained in English, and made available to market surveillance and enforcement authorities at the UK address provided when asked to do so

Labelling & Marking- except for the Responsible Person whereabouts, the marking and labelling requirements would remain unchanged.

REACh- The requirements of GB/EU REACh apply to cosmetic products.

Interested in learning more? Get in touch

What will change for GB and EU- businesses from January 2021?

Responsible Person

GB-based business- There must be a Responsible Person based in the UK under the new regime to allow GB & EU based businesses to place products on the UK market.

·EU-based business- There must be a Responsible Person based in the EU under the current Regulation if GB-based business wants to trade in the EU.

Connect 4 Compliance can act as your UK Responsible Person

Cosmetic Products Notification Portal- CPNP

UK CPNP- The UK Government has established the Submit Cosmetic Product Notification (SCPN) service for this purpose.

Responsible Persons will have 90 days beginning with 1 January 2021 to complete their notification where products were previously notified to the European Commission (EC) via their Cosmetic Product Notification Portal (CPNP), made available on the EEA or UK markets prior to the 31 December 2020, and that they will place those same products on the GB market within 90 days of 1 January 2021.

Placing on the Market- ‘Placing on the market’ means the first making available (supply) of a cosmetic product on the GB market from 31 December 2020.

Safety Assessor- The safety assessor should be in possession of a diploma or other evidence of formal qualifications awarded on completion of a university course of theoretical and practical study in pharmacy, toxicology, medicine or a similar discipline, or a course recognised as equivalent by the Secretary of State.

Interested in learning more? Get in touch

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