Following the UK's exit from the European Union (Brexit), regulations and requirements for cosmetic products in the UK have undergone some changes.
Although many rules remain similar to those in the EU, the UK has established its own regulatory framework to ensure that cosmetic products marketed in its territory comply with safety, quality and labelling standards.
Below are the specific labelling requirements for cosmetic products in the UK, as set out by the UK Cosmetic Regulations.
Table of contents
Cosmetic Product in the United Kingdom: Mandatory Information on Labeling
The labelling of cosmetic products must include a number of key information, which must be clearly visible and legible on the product packaging or container. These requirements ensure that consumers have access to the information necessary for the safe use of the product.
Name and Address of the Controller
Name and address : The name and address of the Responsible Person must be included. The Responsible Person is the entity that ensures that the product complies with UK cosmetic regulations and may be the manufacturer, importer or a designated third party.
Post-Brexit difference : Following Brexit, cosmetic products sold in the UK must list a UK-based Responsible Person, even if the manufacturer or distributor is based outside the UK.
Nominal Content
Product quantity : The packaging must indicate the nominal content of the product. This information must be visible on both the external packaging and the primary packaging, except in the case of small packages of less than 5 grams or 5 ml.
Minimum Durability Date or Period After Opening (PAO)
Expiry date : A minimum shelf life date must be indicated, i.e. the date up to which the product continues to perform its original function safely when stored under appropriate conditions. This date is expressed by the phrase "Best before" or "Use before" and is followed by the date.
Period After Opening (PAO) : If the product has a shelf life of more than 30 months, it is mandatory to display the PAO symbol, which is an image of an open jar, accompanied by the number of months during which the product remains safe and effective once opened.
Precautions for Use
Warnings and precautions : If a cosmetic product requires specific conditions of use or warnings to ensure consumer safety, these must be clearly stated. This is especially important for products that contain ingredients that could cause irritation or that are sensitive to specific storage conditions.
Examples of warnings may include "Avoid contact with eyes" or " Do not apply to damaged skin."
Ingredients
List of ingredients : It is mandatory to list all the ingredients of the product in descending order of weight at the time of their incorporation into the product. The ingredients must be indicated using their INCI nomenclature (International Nomenclature of Cosmetic Ingredients). Also fragrances and colorants and their allergens.
Batch Identification
Batch number : A batch number or manufacturing reference must be included to identify the batch of the product. This is crucial for product traceability in case it needs to be recalled for safety reasons.
Product Function
Product Function : If it is not clear from the product presentation, the labeling should include a description of its function. This ensures that the consumer understands the purpose of the product, whether it is a moisturizer, shampoo, deodorant, etc.
Cosmetic Labelling in the UK: Language on Labelling
Cosmetic product labelling must be in English, as it is the official language of the United Kingdom. Any other information in additional languages may be included, but mandatory information must be available in English to ensure that consumers can understand instructions for use, warnings and ingredients.
Cosmetics in the UK: Additional Symbols on Labelling
In addition to the mandatory information above, cosmetic products in the UK may include certain standard symbols that help consumers understand the product and how to handle it correctly:
PAO Symbol (Period After Opening)
As mentioned above, the PAO symbol is an open jar with a number of months in or near it, indicating how long the product is safe after it has been first opened.
Green Dot Symbol
The Green Dot symbol may appear on some cosmetic product packaging, indicating that the manufacturer contributes to recycling and waste recovery systems.
Recycling Symbol (Mobius Loop)
This symbol, represented by a triangle with arrows, indicates that the packaging is recyclable. It is important to promote sustainable practices in the disposal of packaging.
"Not tested on animals" symbol
In the UK and EU, testing cosmetics on animals is prohibited. Some products may carry symbols indicating that the product has not been tested on animals, such as the Leaping Bunny logo, to reassure ethical consumers.
Cosmetics in the UK: Post-Brexit Adaptations
Following Brexit, the UK has adopted its own regulatory framework for cosmetics, known as the UK Cosmetics Regulation (an adaptation of EU Regulation (EC) 1223/2009). Key changes include:
UK Responsible Person: The regulations state that there must be a Responsible Person based in the UK. If the product is manufactured outside the UK, the company must appoint an entity or person in the UK to be responsible for the product's compliance with UK regulations.
Notification of cosmetic products : Cosmetic products marketed in the UK must be notified on the UK notification portal, known as Submit Cosmetic Product Notification (SCPN), in a similar way to how it was done on the European portal before Brexit.
OPSS: Compliance and Sanctions
UK authorities, such as the Office for Product Safety and Standards (OPSS), are responsible for ensuring that cosmetic products comply with all labelling regulations. If a product does not comply with labelling requirements, the manufacturer or distributor may face penalties, which may include product recall or financial penalties.
Conclusion
Labelling of cosmetic products in the UK remains a key aspect to ensure consumer safety and compliance with local regulations. Companies must ensure that they include all mandatory information, from the list of ingredients to warnings for use, as well as comply with new post-Brexit UK provisions, such as the appointment of a Responsible Person in the country.
Complying with these requirements is not only essential to avoid legal penalties, but also to maintain consumer confidence and encourage safe use of products.
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