Ana Quevedo, Technical Sales Manager, and Chris Longmore, Scientific Account Manager, recently attended the CTPA open webinar on UK regulations for cosmetics. Although the Cosmetic and Chemical industries are currently faced with a number of changes, there are many similarities between the new UK regulations and it’s EU counterpart. For example, the animal testing ban has been completely replicated in the UK. We’ve summarised what we know so far about post-Brexit cosmetic regulations – let’s go!
Provision of goods placed on the market under the withdrawal agreement
Goods placed on the EU or UK markets before the end of the transition period (1st January 2021) can continue to be sold as they were effectively compliant at the time of being placed on the market. But any product placed on the market after 1st January 2021 will have to comply with UK legislation if placed on the GB market or EU regulation if placed on the EU and NI markets. This means that if you’re selling UK wide you need to comply with both EU and UK legislation.
It’s important to remember that any new batch of a product will need to be updated with the UK or EU Responsible Person’s (RP) address.
Great Britain is no longer under the management of the ECHA, instead the HSE has taken on this role, but Northern Ireland (NI) will continue to follow EU rule.
There are currently concerns about arrangements for data sharing and repeat testing, including animal tests. This is a major concern to industry and is under review. ‘New’ substances (substances that are not currently registered under EU REACH) must be registered before placing them on the market. The main provisions of UK REACH remain in place with the requirements being the same as they were for EU REACH. For example, 1 substance for 1 dossier is still applicable.
Technical Barriers to Trade
Although there are no particular sector considerations for the cosmetics industry, there is one for chemicals. Reflected in the EU-UK Trade and Cooperation Agreement (TCA) is a commitment to ongoing cooperation and exchange of non-confidential information. This means information that is publicly available, for example those found on the ECHA website. From a UK perspective, a meaningful conversation between the UK and the EU is on the cards which could create an opportunity for the sharing of scientific information, leading to a better management of chemicals.
Support for SME’s will be provided, with a main focus around the access to information to ensure that SMEs understand how to comply with relevant legislation.
Labelling remains the same in terms of what needs to be added to the label in the EU, with the only change being swapping the EU RP name and address with the UK one.
Any ingredient management occurring after 1st Jan 21 will be independent to the EU. The UK is implementing its own independent pool of scientists to review and assess the safety of cosmetic ingredients and then will take any decision in terms of restricting or banning ingredients. This is where we will possibly see different decisions being made between the EU and the UK in terms of ingredients.
For more information on compliance with the UK Cosmetics Regulation for the GB market, and compliance with the EU Cosmetics Regulation for the EU and Northern Ireland markets, check the CTPA Guides on Supplying Cosmetics Products, which can be downloaded here.