Before Brexit, many cosmetic businesses could manage UK and EU market access through a single regulatory structure. That changed when the UK left the European Union. Today, brands selling cosmetics in both Great Britain and the EU need to understand two separate regulatory environments. The distinction is particularly important for businesses based outside the UK or EU that want to sell products into both markets.

The short answer to the question “Do I need a UK Responsible Person and an EU Responsible Person after Brexit?” is:

If you are placing the same cosmetic products on both the Great Britain and EU markets, you will generally need a Responsible Person arrangement that satisfies the requirements of each market. This can mean a UK-established RP for GB and an EU-established RP for the EU.

The important exception is Northern Ireland, where the EU Cosmetics Regulation continues to apply under the Windsor Framework.

This means that businesses cannot simply assume that one UK address or one EU address will automatically satisfy every UK and EU cosmetic requirement.

Reviewed by Deepa Sinha – Co-founder and CTO at GCRS Group

Key Takeaways

• Brexit created separate cosmetic compliance regimes for Great Britain and the European Union.
• A cosmetic product placed on the Great Britain market generally needs a Responsible Person established in the UK.
• A cosmetic product placed on the EU market needs a Responsible Person established within the EU or EEA framework applicable to the product.
• A UK-established Responsible Person cannot simply act as the EU Responsible Person for products placed directly on the EU market.
• Northern Ireland is different because EU Cosmetics Regulation continues to apply there under the Windsor Framework.
• Brands selling in both GB and the EU may therefore need two Responsible Person arrangements, one covering GB and another covering the EU.
• The Responsible Person role involves much more than providing an address. It carries important responsibilities for product safety, documentation, notification, labelling, claims and post-market compliance.
• A coordinated compliance strategy can help brands avoid duplicated work while keeping market-specific legal responsibilities separate.

What Changed for Cosmetics After Brexit?

The UK left the EU single market and customs union at the end of the Brexit transition period on 31 December 2020.

For cosmetics, this resulted in separate requirements for Great Britain and the EU.

For products placed on the GB market, the UK has its own version of the EU Cosmetics Regulation as retained and amended in UK law. GOV.UK confirms that a cosmetic product cannot be placed on the GB market unless there is a Responsible Person established in the UK, subject to specific provisions for qualifying Northern Ireland goods.

For products placed on the EU market, the EU Cosmetics Regulation continues to require a Responsible Person established within the EU.

This creates a fundamental market-access distinction:

Great Britain = UK regulatory framework

European Union = EU regulatory framework

Northern Ireland = EU Cosmetics Regulation under the Windsor Framework

Understanding these three positions is the starting point for determining your Responsible Person requirements.

What Is a Responsible Person?

A Responsible Person is the individual or legal entity responsible for ensuring that a cosmetic product complies with the applicable cosmetic legislation.

The role is not simply to provide a local address for a product label.

A Responsible Person has regulatory responsibilities that can include:

• Maintaining the Product Information File
• Ensuring the product has undergone the required safety assessment
• Checking compliance with ingredient restrictions
• Ensuring appropriate product notification
• Reviewing labelling requirements
• Supporting claims compliance
• Maintaining relevant documentation
• Cooperating with competent authorities
• Managing or supporting Serious Undesirable Effect reporting
• Taking appropriate action when a product presents a compliance or safety issue

For GB, GOV.UK specifically states that the Responsible Person must ensure legal obligations are met and must support areas including the Product Information File, labelling, notification, safety and serious harmful effects.

This is why choosing an appropriate UK Responsible Person should be treated as a regulatory decision rather than simply a commercial service purchase.

Do You Need a UK Responsible Person for Great Britain?

Yes, if your cosmetic product is being placed on the Great Britain market and you do not otherwise meet the conditions for being the Responsible Person yourself.

Great Britain consists of:

• England
• Scotland
• Wales

GOV.UK states that cosmetic products made available to consumers in Great Britain must have a Responsible Person with a UK-established address.

The Responsible Person can, depending on the circumstances, be:

• The manufacturer
• The importer
• A distributor placing the product under its own name or trademark
• An appointed third-party company or person

For businesses outside the UK, appointing a UK-established third party is often the practical route.

What Does the UK RP Need to Do?

The GB Responsible Person has responsibilities under the UK cosmetic regulatory framework.

These include ensuring that:

• The cosmetic product is safe
• Required safety information is available
• The Product Information File is maintained
• Labelling complies with applicable requirements
• The product is notified to the UK authorities
• Relevant adverse or serious undesirable effects are managed
• Cosmetic claims can be substantiated
• Regulatory authorities can access required information

GOV.UK confirms that GB cosmetic products must be notified through the UK Submit Cosmetic Product Notification system, commonly referred to as SCPN, through the Responsible Person.

As of 28 May 2026, the UK government reported 861,686 notifications in the SCPN system and 24,112 registered Responsible Persons, illustrating the scale of the GB notification system.

Do You Need an EU Responsible Person?

Yes, if you are placing a cosmetic product on the EU market and the manufacturer is not established in the EU, the product needs an EU-established Responsible Person.

The EU Cosmetics Regulation is based on the principle that every cosmetic product placed on the EU market must have a Responsible Person established within the appropriate EU territory.

For a UK brand selling directly into the EU after Brexit, the UK address on its own does not fulfil the EU Responsible Person requirement.

This means that a UK cosmetic brand selling products into France, Germany, Italy, Spain or another EU Member State may need an EU-based Responsible Person.

The EU RP also has responsibilities under the EU Cosmetics Regulation, including ensuring that the product complies with applicable requirements and that the relevant product documentation and notification obligations are addressed.

Why Can’t Your UK RP Simply Act as Your EU RP?

This is one of the most common misunderstandings after Brexit.

A UK-established Responsible Person is not automatically eligible to act as the Responsible Person for a cosmetic product placed directly on the EU market.

The EU and GB regimes require the Responsible Person to be established in the relevant territory.

This is why a business selling in both markets may need:

UK RP → Great Britain

EU RP → European Union

The two roles may be managed by the same regulatory service provider where the provider has appropriately established entities and accepts the relevant responsibilities, but the legal market requirements still need to be satisfied separately.

The key point is that one service provider does not necessarily mean one legal Responsible Person arrangement.

What About Northern Ireland?

Northern Ireland requires special consideration.

Unlike Great Britain, EU Cosmetics Regulation continues to apply to cosmetic products placed on the Northern Ireland market under the Windsor Framework.

GOV.UK confirms that a Responsible Person for cosmetics placed on the NI or EEA market must be established in Northern Ireland or the EU. A Responsible Person based in Great Britain cannot fulfil the EU Responsible Person role for these products.

This means:

What If You Sell in Both NI and GB?

This is where the situation becomes more nuanced.

A business placing products on both markets may have obligations under both systems.

For example, GOV.UK explains that products placed on the NI market may need notification through the EU CPNP, while products also placed on the GB market require notification through the UK SCPN system.

Therefore, businesses should map their actual supply chain and market route rather than assuming that a single notification or Responsible Person arrangement covers the entire UK.

UK RP vs EU RP: What Is the Difference?

Although both roles are based on the concept of regulatory responsibility, their legal responsibilities arise from different regulatory frameworks.

The exact obligations can depend on how the product is manufactured, imported, distributed and placed on each market.

This is why market mapping should happen before finalising your Responsible Person structure.

Do You Need Two Product Information Files?

Not necessarily in the sense of creating two completely independent technical dossiers from scratch.

A well-prepared regulatory dossier can often provide a common technical foundation for multiple markets.

However, the legal and regulatory requirements applied to that information can differ.

For example, the product may require different:

• Responsible Person details
• Notification records
• Labelling information
• Market-specific documentation
• Importer information
• Regulatory assessments
• Post-market procedures

The goal should therefore not be to duplicate everything unnecessarily.

Instead, brands should build a strong core product compliance file and then adapt the relevant regulatory elements for each market.

This approach can reduce duplication while maintaining compliance.

Does the Same Cosmetic Label Work in the UK and EU?

Not necessarily.

Brexit created market-specific labelling considerations.

For products placed on the GB market, the Responsible Person’s UK address is relevant to the product label.

For products placed on the EU market, the appropriate EU Responsible Person information must be provided.

There can also be differences in:

• Language requirements
• Importer information
• Country of origin
• Product claims
• Ingredient restrictions
• Local regulatory expectations

The label should therefore be reviewed against the requirements of each market before production.

This is particularly important for brands using one global artwork file.

A label that is compliant for one market is not automatically compliant for another.

What Happens to CPNP and SCPN After Brexit?

Brexit separated the UK and EU cosmetic notification systems for the relevant markets.

CPNP

The Cosmetic Products Notification Portal, or CPNP, is the EU notification system.

Products placed on the EU market under the EU Cosmetics Regulation are notified through CPNP.

For Northern Ireland, the EU notification system continues to apply under the Windsor Framework. GOV.UK confirms that the Responsible Person for NI or EEA products must notify through the CPNP.

SCPN

The Submit Cosmetic Product Notifications system is used for cosmetic products placed on the Great Britain market.

GOV.UK states that GB cosmetic products must be notified through the SCPN service.

This creates another important distinction:

EU / NI → CPNP

GB → SCPN

A business selling throughout the UK and EU therefore needs to understand which products belong in which system.

What Happens If You Use Only an EU RP for the UK Market?

If your product is being placed directly on the Great Britain market, an EU-only Responsible Person arrangement will generally not satisfy the GB Responsible Person requirement.

GOV.UK states that a cosmetic product cannot be placed on the GB market unless there is a Responsible Person established in the UK, subject to specific provisions for qualifying Northern Ireland goods.

This can affect:

• Product labelling
• SCPN notification
• Product Information File availability
• Regulatory communications
• Post-market responsibilities
• Market surveillance

The same principle works in reverse.

An EU-only RP does not automatically satisfy the requirements for direct GB market access, and a UK-only RP does not automatically satisfy the EU Responsible Person requirement.

What Happens If You Use Only a UK RP for the EU Market?

A UK-established RP cannot simply fulfil the EU Responsible Person requirement for a product placed directly on the EU market.

If a UK brand wants to sell directly into the EU, it should establish an appropriate EU Responsible Person arrangement.

This is particularly important for e-commerce brands.

Selling through an online store does not remove regulatory obligations simply because the product is shipped directly to consumers.

The commercial sales model needs to be considered alongside the regulatory supply chain.

Do You Need a UK RP and EU RP If You Sell Through a Distributor?

Possibly, depending on the supply chain and contractual arrangements.

A distributor can have certain regulatory responsibilities depending on its role, the product’s origin, branding and how the product is placed on the market.

However, brands should not assume that appointing a distributor automatically removes their regulatory responsibilities.

Before signing a distribution agreement, clarify:

• Who is the importer?
• Who is the Responsible Person?
• Where is the Responsible Person established?
• Who manages product notification?
• Who holds the Product Information File?
• Who manages regulatory authorities?
• Who handles Serious Undesirable Effects?
• Who manages recalls?
• Who approves label changes?
• Who controls regulatory documentation?

A clear allocation of responsibilities can prevent significant compliance problems later.

Can One Company Manage Both UK and EU RP Services?

Yes, a business can work with a single compliance provider for both markets if that provider has the appropriate legal structures and accepts the relevant Responsible Person appointments.

This can be commercially useful because it gives the brand one central compliance relationship.

However, the underlying legal requirements do not disappear.

A provider may manage both:

UK Responsible Person services

and

EU Responsible Person services

while maintaining the appropriate market-specific responsibilities, notifications and documentation.

For brands, the benefit is operational simplicity without treating the UK and EU as one regulatory market.

How Compliance Automation Can Help Manage UK and EU RPs ?

Managing two regulatory environments can become difficult as a brand grows.

A business may need to track:

• Products
• Formulations
• PIFs
• Safety assessments
• Labels
• Notifications
• Responsible Person details
• Regulatory changes
• Product updates
• Supplier information
• Post-market events

This is where compliance automation can support a more structured workflow.

Technology can help teams:

• Centralise product information
• Track market-specific requirements
• Monitor documentation status
• Manage approval workflows
• Track regulatory changes
• Reduce duplicated administration
• Maintain visibility across multiple markets

Automation should not replace regulatory expertise.

Its value is in helping businesses manage complex compliance information more efficiently while regulatory specialists make the appropriate decisions.

For brands selling in both the UK and EU, this can be particularly useful because the same product may have different market-specific regulatory requirements.

How GCRS Can Support UK and EU Cosmetic Compliance

Brexit has made UK and EU cosmetic compliance more complex for businesses that want to sell across both markets.

The solution is not simply to appoint two addresses.

Brands need a structured approach covering Responsible Person responsibilities, product documentation, notification, safety, labelling and ongoing compliance.

GCRS provides Responsible Person services for businesses requiring regulatory representation and support across applicable markets.

GCRS can also support the wider regulatory process through compliance services, helping brands connect Responsible Person requirements with product documentation, safety, labelling, claims and market-entry activities.

For brands expanding across multiple products and markets, a structured approach to regulatory data and compliance automation can also help reduce administrative duplication and improve visibility across the compliance lifecycle.

A Practical UK and EU Compliance Checklist

Before selling the same cosmetic product in both markets, confirm:

Great Britain

• UK Responsible Person identified
• UK RP details confirmed for labelling
• Product compliance reviewed
• Safety assessment completed
• Product Information File maintained
• GB labelling reviewed
• SCPN notification completed
• Post-market procedures established

European Union

• EU Responsible Person identified
• EU RP details confirmed for labelling
• EU product compliance reviewed
• Safety assessment completed
• Product Information File maintained
• EU labelling reviewed
• CPNP notification completed
• Post-market procedures established

Northern Ireland

• EU Cosmetics Regulation requirements reviewed
• NI or EU Responsible Person identified where required
• CPNP notification completed where applicable
• NI-specific market route assessed
• GB supply route assessed if the product is also sold in GB

Conclusion

So, do you need a UK Responsible Person and an EU Responsible Person after Brexit?

If you are placing cosmetic products directly on both the Great Britain and EU markets, you generally need Responsible Person arrangements that satisfy the requirements of both jurisdictions.

The UK RP supports the Great Britain market under the UK cosmetic regulatory framework.

The EU RP supports the EU market under the EU Cosmetics Regulation.

Northern Ireland is different because EU cosmetic rules continue to apply there under the Windsor Framework, meaning an NI or EU-established Responsible Person can fulfil the relevant role for products placed on the NI market.

The important point is that Brexit did not simply create a requirement for “another address”. It created separate regulatory responsibilities, notification systems and market-access requirements.

For brands operating across both markets, the most efficient strategy is to create one coordinated compliance framework while keeping the legal requirements of each market clearly separated.

That approach can reduce duplicated work, prevent avoidable labelling and notification errors, and make international expansion easier to manage.

Need UK and EU Responsible Person Support?

If your cosmetic brand sells, or plans to sell, in both Great Britain and the EU, GCRS can help you establish the appropriate Responsible Person structure and connect it with your wider regulatory compliance programme.

Speak to GCRS about UK and EU Responsible Person requirements and build a compliant market-entry strategy for your cosmetics.

FAQs

1. Do I need a UK Responsible Person after Brexit?

Yes, cosmetic products placed on the Great Britain market generally need a Responsible Person established in the UK. The RP has responsibilities covering areas such as product safety, documentation, labelling, notification and post-market compliance.

2. Can my UK Responsible Person also be my EU Responsible Person?

A UK-established Responsible Person cannot automatically fulfil the EU Responsible Person requirement for a product placed directly on the EU market. The EU Responsible Person needs to be established within the EU. Therefore, businesses selling directly in both markets generally need arrangements that satisfy both jurisdictions.

3. Does Northern Ireland need a UK or EU Responsible Person?

For cosmetics placed on the Northern Ireland market under the Windsor Framework, the Responsible Person must be established in Northern Ireland or the EU. The product is subject to the EU Cosmetics Regulation, and relevant notification is made through the CPNP.

4. Do I need both CPNP and SCPN?

If the same cosmetic products are being placed on both the EU or Northern Ireland market and the Great Britain market, the relevant notification systems are different. Products placed on the GB market are notified through SCPN, while products placed on the EU market and applicable products placed on the NI market are notified through CPNP.

ABOUT THE REVIEWER – DEEPA SINHA

Co-founder and CTO at GCRS Group, supporting cosmetic and personal care brands with global regulatory compliance, Responsible Person services, claims review, testing coordination and international market entry strategy across the UK, EU, USA, UAE, India and wider global markets.

She works alongside the wider GCRS regulatory team to help brands navigate evolving cosmetic regulations and launch products compliantly across multiple regions.