Compliance is not a document you buy. It is a set of eighteen things that must all be true at the same time, and a file that proves it. This is the list we work through before any product goes on sale in Great Britain.
The five legal requirements
- A GB-established Responsible Person, appointed in writing, whose name and address appear on the label (mandatory for goods placed on the GB market since 1 January 2026).
- A Cosmetic Product Safety Report signed by a qualified safety assessor, with Part A containing real data and Part B containing the conclusion and any required warnings.
- A Product Information File in English, retained for ten years after the last batch is placed on the market, producible on request within days.
- An SCPN notification submitted to OPSS before the product is made available to consumers. CPNP does not cover Great Britain.
- A compliant label and claims that can be substantiated.
The eighteen-point check
Formula and safety
- Every ingredient is permitted in GB at its use level and product type.
- The formula in the file matches the formula in production, including supplier changes.
- Stability data covers the actual pack, not a generic jar.
- Preservative efficacy has been tested for water-based products.
- Microbiological limits and testing frequency are defined.
- Any nanomaterial, CMR substance or restricted colourant is declared.
Label and artwork
- Responsible Person name and UK address are printed.
- Nominal content, batch code and date of minimum durability or PAO symbol are present and correct.
- INCI list is in descending order, with allergens declared where required.
- Every warning required by Part B of the safety report appears on pack.
- Claims match the evidence file, and no claim drifts into medicinal territory.
File and market
- SCPN reference is recorded against the product and retained.
- A change log exists, so a reformulation or a supplier switch triggers a review rather than silence.
What changed in 2026
| Date | Change | Action |
|---|---|---|
| 1 January 2026 | Responsible Person details must appear on the GB label | Re-check artwork; reprint if the block is missing |
| 15 July 2026 | 4-MBC prohibited; removed from the permitted UV filter list | Reformulate sun care and leave-on products; sell-through to 14 January 2027 |
| 15 August 2026 | Sixteen CMR substances prohibited, including TPO in gel and nail products | Check nail systems first; sell-through to 14 February 2027 |
| 15 August 2026 | Formaldehyde-releaser warning threshold lowered to 0.001% | Review preservative systems and label warnings |
If your safety report was signed before these instruments, it is worth a review. A report that was correct when signed can fall out of date when an ingredient it relies on is restricted.
The failures that get found first
Enforcement is usually triggered by a complaint, a retailer audit or a routine check. The findings are predictable: an unnotified product (provable in minutes on SCPN), a label that does not match the file, a CPSR signed by someone without the qualification, and Part A padded with generic statements that do not describe this product at all.
A valid safety report does not notify your product, and a notification does not make an unsafe product legal. They are separate obligations.
Where brands get stuck
Almost always at the beginning: nobody has written the quantitative formula down in a form an assessor can work from, or the pack has not been fixed so compatibility cannot be tested. Fixing those two inputs typically removes two to three weeks from the compliance stage.
Northern Ireland follows EU rules under the Windsor Framework: CPNP notification and a Responsible Person established in NI or the EU. A brand selling across the whole UK may need two notifications, two Responsible Persons and a label that satisfies both.
Where this sits in a real project
This checklist is the working document behind our UK compliance capability. If you are still deciding whether a product is viable, a feasibility review tests the formula, the claims and the regulatory route before money is committed. How each document is produced and signed off is described under quality and standards, and the same gates appear in printable form in the launch readiness checklist.
Questions we are asked
Who can act as the Responsible Person for Great Britain?
A person or company established in GB who is designated in writing and whose name and address appear on the label. We coordinate the appointment and assemble the technical file that supports them; we do not present a Dubai address as a UK one.
How long must the Product Information File be kept?
Ten years after the last batch of the product was placed on the market. It must be in English and readily accessible to the enforcement authority, which is why we version it alongside artwork and formula changes rather than rebuilding it at the end.
Is an SCPN notification the same as an EU CPNP notification?
No. Great Britain operates its own Submit Cosmetic Product Notifications service. A product notified only through the EU CPNP is not notified for the GB market, and the two regimes also differ on the Responsible Person detail printed on the label.