Submit Cosmetic Product Notification UK: A Guide
On 31 January 2020, the United Kingdom left the European Union, becoming a third country with its own regulations for the various sectors, including the cosmetics sector. The reference regulation for cosmetic products placed on the market in the United Kingdom is “The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, Schedule 34”, the so-called “UK Cosmetics Regulation”.
This regulation is part of the British adaptation of European regulations after Brexit, in particular Regulation (EC) No 1223/2009 on cosmetic products. Consequently, following the UK’s exit from the European Union, it was necessary to establish an independent notification and regulatory system for cosmetics (the Submit Cosmetic Product Notification SCPN UK), which is managed by the Office for Product Safety and Standards (OPSS). The obligation to notify is enshrined in Article 13 of the aforementioned Regulation.
The Submit Cosmetic Product Notification (SCPN)
The UK Cosmetics Portal is a UK government platform designed for the notification of cosmetic products intended for the UK market. After Brexit, the United Kingdom set up its own notification system, clearly separate from the similar system of the European Union, namely the Cosmetic Products Notification Portal (CPNP)
As outlined in the UK Cosmetic Regulation, the Responsible Person is obligated to submit the required information confirming the product’s safety to the Office for Product Safety and Standards (OPSS) through this portal. This process is known as product notification. Notification through the SCPN UK portal is mandatory for any cosmetic product that is introduced into the market of Great Britain (England, Scotland and Wales) and serves to ensure the compliance of products with British regulations.
In this article, we will discuss the registration process, its importance, and how it ensures your products meet the necessary legal requirements for the UK market. To know more about how to achieve regulatory compliance you can read our UK Cosmetic Regulations article.
When Was the SCPN Officially Implemented in the UK?
The requirement to submit cosmetic product notifications to the UK Cosmetics Portal has been in effect since Great Britain’s exit from the European Union in 2021. This applies to England, Scotland, and Wales. Previously, a single notification to the Cosmetic Product Notification Portal (CPNP), the European cosmetic portal, was sufficient. Now, to sell cosmetic products in both the EU and the UK, two product notifications are required: CPNP EU and SCPN UK.
Primary Objectives of The Submit Cosmetic Product Notification
The SCPN is a free online notification system established under Regulation No 1223/2009 for cosmetic products. Its purpose is to ensure the traceability of all cosmetic products on the UK market. While having an SCPN UK notification number does not confirm compliance with the UK Cosmetics Regulation, Enforcement Authorities, such as Trading Standards Officers, use this portal to verify compliance.
The submitted information is accessible to competent authorities for purposes such as market surveillance, analysis, evaluation, and consumer information. It is also available to the National Poisons Information Service (NPIS) to support medical treatment.
Who Does The SCPN Apply To?
If you are making a cosmetic product available to consumers in Great Britain, including England, Scotland, and Wales, your Responsible Person must submit a product notification of your cosmetic product through the cosmetics portal UK, the SCPN.
Only a legal entity, called a “Responsible Person” (RP), can submit the notification for a product. This person can be the manufacturer, importer, or a designated representative based in the UK.
Submit Cosmetic Product Notification SCPN UK Process
To submit a cosmetic product to the SCPN, you must first create an account on the portal. Next, you will need to answer a series of questions about the product. Before finalising the process, you can review all the uploaded information to ensure accuracy before you submit cosmetic product notification. Once submitted, you will have 7 days to review and edit any data if errors are identified.
If your cosmetic product contains nanomaterials, it must be notified six months before being placed on the market. After completing all required steps, the SCPN will provide a reference number. This reference number must be included in the product’s PIF (Product Information File).
Information Required to Be Submitted Through the SCPN
Among the information required by the SCPN UK at the time of notification are:
- The category of cosmetic product and its name or names, enabling its specific identification.
- The name and address of the UK Responsible Person.
- The address at which the cosmetic product information file (PIF) is kept.
- The contact details of a natural person to contact in the case of urgency.
- If applicable, the following information
(I) The presence of any nanomaterials in the product.
(II) The identification including the chemical name (IUPAC) and other descriptors as specified in point 2 of the Preamble to Annexes 2 to 6 to this Regulation.
(III) The reasonably foreseeable exposure conditions.
- The name and the Chemicals Abstracts Service (CAS) or EC number of substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) of category 1A or 1B under Regulation (EC) No 1272/2008.
- The frame formulation allowing for prompt and appropriate medical treatment in the event of difficulties.
- The original labelling and, where reasonably legible, a photograph of the corresponding packaging.
Once registration is complete, the product receives an SCPN registration number and a PDF report that contains a summary of the information entered. This number is essential for product identification in the event of verification by regulatory authorities.
Are There Any Exemptions or Specific Categories of Cosmetic Products Not Covered by the SCPN?
All cosmetic products must be notified in the SCPN UK portal, without exceptions.
As stated in Article 2 of the UK Cosmetic Regulation, the definition of a cosmetic product comprises three parts: a function, field of application, and product composition. All parts of the definition must be satisfied for the product to be considered a cosmetic.
The Regulation specifies six functions in relation to external parts of the human body for products that may be cosmetic products: to clean, to perfume, to change the appearance, to protect, to keep in good condition and to correct body odours. Additionally, cosmetics can only be applied to the external parts of the human body: the epidermis, the hair system, the nails, the lips, the external genital organs, the teeth and the mucous membranes of the oral cavity.
Consequences of Non-Compliance with UK Cosmetics Portal Requirements
Failing to submit cosmetics to the SCPN, the UK cosmetics portal, constitutes non-compliance with the UK Cosmetic Regulation 1223/2009. This can result in fines—unlimited in England and Wales or up to £5,000 in Scotland and Northern Ireland—and a prison term of up to 3 months.
Is There a Designated Responsible Person Required for Each Product Under the SCPN?
The Responsible Person is the individual or company responsible for ensuring the cosmetic product complies with UK Cosmetic Regulations throughout its time on the market. Their contact information must always be kept up to date on the SCPN, as competent authorities may reach out regarding the product.
For foreign cosmetics companies that want to sell in the UK, the requirement to appoint a UK-based Responsible Person presents a new challenge. Many companies rely on consultants or representative firms to handle registrations and make sure their products meet local requirements. For more details on the role of the Responsible Person, see our article on the Responsible Person in cosmetics.
Updates or Amendments to Product Notifications Within the SCPN System
Companies are responsible for keeping the information in the SCPN portal up to date. Any changes to a cosmetic product—its formula, label or packaging—must be reassessed to ensure compliance with UK Cosmetic Regulations. These updates must also be notified to the UK Cosmetics Portal to ensure that product information remains accurate throughout the product’s lifecycle in the UK market.
If the cosmetic product is no longer sold in the UK, the Responsible Person must notify this in the SCPN UK portal to remove products that are no longer distributed.
In summary, the SCPN UK portal is an essential tool to ensure that cosmetics placed on the UK market comply with the safety and transparency standards required by local legislation.
How Does the Notification System Contribute to Consumer Safety and Market Surveillance in the Cosmetics Industry?
Through the product notification, the information of the cosmetic product will be accessible to the competent authorities responsible for market surveillance, market analysis, evaluation, and consumer information. All product details will also be available to the UK Poison Centre, The National Poisons Information Service (NPIS), and similar bodies for medical treatment in case of emergencies.
Are There Any Provisions to Safeguard Sensitive Information Provided by Companies Through the SCPN?
The SCPN is an official government database, ensuring that confidential information submitted by the Responsible Person to the cosmetics portal UK is secure and not open to the public. This ensures that the technical and commercial details of the formulations and substances contained in the products are protected.
Only regulatory authorities, such as customs or control officials, can access information to verify a product’s compliance.
What Role Does the UK Cosmetic Portal Play in Ensuring Compliance with Relevant Cosmetic Regulations?
According to the UK Cosmetics Regulation (EC) No. 1223/2009 (UKCR) for cosmetics marketed in Great Britain (England, Wales, and Scotland), it is mandatory to notify every cosmetic product in the UK Cosmetic Portal. Enforcement authorities, such as Trading Standards Officers, can access the SCPN to conduct inspections and verify the compliance of cosmetic products sold in the UK.
Is There a Specific Authority Responsible for Overseeing the SCPN Process in the UK?
The UK Cosmetics Regulation is enforced in Great Britain via the UK Cosmetic Products Enforcement Regulations 2013 which specifies the role of the authorities, the penalties and the enforcement process. The UK Government Department for Business and Trade (DBT) and the Office for Product Safety and Standards (OPSS) are the UK Competent Authorities for implementing the legislation for cosmetic products.
The UK cosmetic portal SCPN, as we have seen, is managed by the UK government’s Office for Product Safety and Standards (OPSS). They ensure that the information related to cosmetic products is accurate and compliant with the UK Cosmetic Regulations.
Conclusion
However, notification to the SCPN portal is only one of the many obligations that accompany the life of a cosmetic product in the UK.
Do you need to submit a Cosmetic Product Notification in the UK? Taobé Consulting can handle it for you. Contact us for expert advice on bringing your products up to standard, including notification to the cosmetics portal UK, cosmetic PIF preparation, formula compliance, and more.
Let us help you get your cosmetic products registered in the UK.