Compliance Checklist

GPSR (General Product Safety Regulation)
Beauty & Cosmetics
United Kingdom 🇬🇧

UK product safety for cosmetics and beauty products on Amazon UK: UK Cosmetics Regulation, SCPN notification, UK Responsible Person and common mistakes.

Overview

In the United Kingdom, cosmetic products are subject to a standalone regulatory framework decoupled from the EU Cosmetics Regulation after Brexit. The UK Cosmetics Regulation (building on the retained EU Regulation 1223/2009) forms the basis. Instead of the EU CPNP, products must be notified via the Submit Cosmetic Product Notification (SCPN) portal of the British Office for Product Safety and Standards (OPSS). A UK Responsible Person is mandatory for all non-UK manufacturers. Unlike the EU GPSR, the UK continues to apply the General Product Safety Regulations 2005 as general product safety law – the UK has not adopted the EU GPSR 2023.

Does this apply to my product?

This checklist applies to all cosmetic and beauty products sold on Amazon.co.uk: skincare products, make-up, hair care products, perfumes, deodorants, nail polishes, sun protection products, toothpaste, soaps, bath additives and all substances or mixtures intended to come into contact with external body parts (skin, hair, nails, lips, teeth, oral mucosa) for the purpose of cleaning, perfuming, protecting, keeping in good condition or changing appearance.

Step-by-Step Guide

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Appoint UK Responsible Person and prepare Cosmetic Product Safety Report

The UK Responsible Person is the central figure in UK cosmetics regulation. They must hold the Cosmetic Product Safety Report (CPSR) and are responsible for product safety.

Estimated time: 2-4 weeks

UK Responsible Person with UK address appointedRequired

The UK RP must be a natural or legal person based in Great Britain. They are legally responsible for cosmetic product conformity, hold the CPSR and report serious undesirable effects to OPSS.

Agreement with UK Responsible Person

Cosmetic Product Safety Report (CPSR) preparedRequired

The CPSR must be prepared by a qualified Safety Assessor and contain Part A (safety information: composition, physical/chemical properties, microbiological quality, impurities, packaging, conditions of use, exposures, toxicological profiles) and Part B (safety assessment and conclusion).

Cosmetic Product Safety Report (CPSR) Part A and B

Submit SCPN notification

Before placing on the UK market, every cosmetic product must be notified via the OPSS SCPN portal. This replaces the EU CPNP notification.

Estimated time: 1-3 days

Product registered in SCPN portalRequired

Register the product providing: product category, product name, UK Responsible Person, frame formulation or exact composition, original packaging photo, label. The notification must be completed before the first sale in the UK.

SCPN registration confirmation

Ingredient list prepared according to UK requirementsRequired

All ingredients must be listed according to INCI nomenclature. Check the UK-specific lists of prohibited and restricted substances (Annexes of the UK Cosmetics Regulation) – these may differ from EU lists.

Adapt labelling and packaging for UK market

Cosmetic products in the UK must meet specific labelling requirements that partially differ from EU requirements.

Estimated time: 1-2 weeks

Mandatory information on packaging in English presentRequired

Mandatory information: name/address of UK Responsible Person, nominal content (weight/volume), best before date or PAO symbol, INCI ingredient list, batch number, product function (if not obvious), special precautions. Everything in English.

Prohibited claims avoided (no medicinal claims)Required

Cosmetic claims must not suggest medicinal or therapeutic effects. The Advertising Standards Authority (ASA) and Trading Standards monitor this strictly. Avoid phrases like 'heals', 'treats', 'medically effective'.

Meet Amazon.co.uk compliance requirements

Ensure your beauty listing on Amazon.co.uk meets all platform-specific requirements.

Estimated time: 2-5 days

UK Responsible Person registered in Seller CentralRequired

Register the UK RP with full address in Seller Central. Amazon increasingly requires this for beauty products and may deactivate listings without this information.

CPSR and SCPN confirmation kept ready for Amazon complianceRequired

Keep the CPSR, SCPN registration confirmation and further safety data if applicable ready. Amazon may request these documents at any time, particularly following customer complaints or compliance spot checks.

CPSR, SCPN confirmation, safety data sheets

Common Mistakes to Avoid

Considered EU CPNP notification as sufficient for the UK market

Consequence: The EU CPNP notification has no validity in the UK. Products without SCPN notification are sold illegally in the UK. OPSS can impose fines and prohibit sales.

Prevention: Carry out a separate SCPN notification via the OPSS portal for each product, independent of the EU CPNP notification.

UK Responsible Person address on packaging is missing or is an EU address

Consequence: A missing or incorrect RP address makes the product not marketable in the UK. Amazon may block listings and authorities can seize products.

Prevention: Ensure a British address of the UK Responsible Person is on the packaging. For multilingual packaging, the UK address can be stated in addition to the EU address.

Prohibited or restricted ingredients not checked against UK list

Consequence: UK lists may differ from EU lists. A substance permitted in the EU may be prohibited in the UK and vice versa. Selling products with prohibited substances is a criminal offence.

Prevention: Check the Annexes of the UK Cosmetics Regulation separately. Have your Safety Assessor confirm UK-specific requirements.

Serious undesirable effects not reported to OPSS

Consequence: The UK Responsible Person is legally obliged to report serious undesirable effects to OPSS. Failure to report can lead to fines and sales prohibitions.

Prevention: Set up a cosmetovigilance system. Ensure your UK RP is informed about customer complaints and knows reporting obligations.

Frequently Asked Questions

Q1Do I need a separate CPSR for the UK market?

An existing EU CPSR can serve as a basis but must be reviewed for UK-specific requirements and adapted if necessary. The UK Cosmetics Regulation has its own Annexes for prohibited and restricted substances, which may differ.

Q2What is the difference between UK product safety and EU GPSR for cosmetics?

The UK has not adopted the EU GPSR (Regulation 2023/988). In the UK, the General Product Safety Regulations 2005 continue to apply as a general safety net, while cosmetics primarily fall under the UK Cosmetics Regulation. In the EU, the GPSR has been the overarching product safety law since December 2024.

Q3Do I need a separate SCPN notification for each colour variant?

Yes, each product variant with a different composition requires its own SCPN notification. For purely cosmetic colour variants with identical base formula, a shared notification may be possible – check this in the SCPN portal.

Q4What qualification does the Safety Assessor need for the CPSR?

The Safety Assessor must hold a diploma or degree in pharmacy, toxicology, medicine, dermatology or a similar discipline. In practice, CPSRs are often prepared by specialised consultancy firms.

Q5Does this checklist also apply to natural and vegan cosmetics?

Yes. Natural and vegan cosmetics are subject to the same regulatory requirements as conventional cosmetics. Additional claims like 'natural' or 'vegan' must be substantiated and not misleading (ASA guidelines).

GPSR (General Product Safety Regulation)Beauty & CosmeticsUnited Kingdom 🇬🇧

Appoint UK Responsible Person and prepare Cosmetic Product Safety Report

Submit SCPN notification

Adapt labelling and packaging for UK market

Meet Amazon.co.uk compliance requirements

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