Compliance Checklist

GPSR (General Product Safety Regulation)
Personal Care
United Kingdom 🇬🇧

UK product safety for personal care products (toothpaste, deodorant, shaving, sunscreen, soap, intimate care) on Amazon.co.uk: UK Cosmetics Regulation, SCPN notification, UK Responsible Person, UKCA transition, and common mistakes.

Overview

Since Brexit, the United Kingdom is NOT covered by the EU General Product Safety Regulation (GPSR, EU 2023/988). Instead, the UK operates its own framework: the General Product Safety Regulations 2005 (GPSR UK, SI 2005/1803) as the general product safety law, supplemented by the Consumer Protection Act 1987 and — specifically for personal care products — the UK Cosmetics Regulation (the retained version of EU Regulation (EC) No 1223/2009) together with the Cosmetic Products Enforcement Regulations 2013 (SI 2013/1478). Instead of notifying via the EU's CPNP portal, personal care products must be notified through the Submit Cosmetic Product Notification (SCPN) system operated by the Office for Product Safety and Standards (OPSS). For any product originating from a manufacturer outside Great Britain, a UK Responsible Person (UK RP) with a British address is mandatory — this is a distinct role from an EU Responsible Person and must be appointed separately. UKCA marking is gradually replacing CE marking for the GB market, though CE continues to be accepted until the end of 2027. English-language labelling is sufficient for the UK market; no additional language is required. Amazon.co.uk increasingly requires proof of the UK Responsible Person to be entered directly in Seller Central for personal care products.

Does this apply to my product?

This checklist applies to all personal care products sold on Amazon.co.uk, including: toothpaste and oral care products, deodorants and antiperspirants, shaving products (shaving foam, gel, oil, aftershave), sunscreen and self-tanning products, soaps and shower products, intimate care products and wet wipes, and hand creams and body lotions. These products are legally classified as cosmetics under the UK Cosmetics Regulation and are additionally subject to the general requirements of GPSR UK 2005. Products with a medicinal purpose (e.g. medical devices or medicines) are not covered and fall under separate MHRA regulations.

Step-by-Step Guide

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Appoint UK Responsible Person and Determine Role

Determine your role as an economic operator and appoint a UK-based Responsible Person. This person carries central legal responsibility for product safety on the UK market.

Estimated time: 1-2 weeks

Determine economic operator roleRequired

Determine whether you qualify as a manufacturer (produced under your own brand or contract-manufactured), importer (first placing of a non-UK product on the Great Britain market), or distributor (further distribution of a product already placed on the Great Britain market). Private-label sellers are legally treated as manufacturers with the full scope of obligations.

Contractual agreements with suppliers and manufacturers

Appoint UK Responsible Person with UK addressRequired

Appoint a UK Responsible Person (UK RP) under the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 and the UK Cosmetics Regulation. The UK RP must be a natural or legal person established in Great Britain and is responsible for: holding the Cosmetic Product Safety Report (CPSR), cooperating with OPSS and Trading Standards, reporting serious undesirable effects (cosmetovigilance), and ensuring ongoing conformity. The UK RP is NOT the same as an EU Responsible Person — both roles must be filled separately if you sell in both the EU and the UK.

Authorisation agreement with UK Responsible Person including liability provisionsProof of British business address of the UK Responsible Person

Prepare Safety Assessment and Cosmetic Product Safety Report (CPSR)

Have a safety assessment prepared under the requirements of the UK Cosmetics Regulation by a qualified safety assessor. This forms the technical basis for the subsequent SCPN notification.

Estimated time: 2-5 weeks

Commission CPSR Part A and Part BRequired

The Cosmetic Product Safety Report (CPSR) must be prepared by a qualified safety assessor (holding a diploma/degree in pharmacy, toxicology, medicine, dermatology, or a similar discipline). Part A covers safety information: quantitative and qualitative composition, physicochemical properties and stability, microbiological quality, impurities and packaging material, conditions of use and exposure, toxicological profile of the ingredients. Part B contains the actual safety assessment and the assessor's reasoned conclusion.

Cosmetic Product Safety Report (CPSR) Part A and Part B

Check ingredients against UK-specific prohibited/restricted listsRequired

Check all ingredients against the Annexes of the UK Cosmetics Regulation (prohibited substances, restricted substances, permitted colourants, preservatives, and UV filters). These lists have been decoupled from the EU Annexes since Brexit and may now differ — a substance permitted in the EU (e.g. a newly regulated UV filter for sunscreen products) may be treated differently in the UK and vice versa.

Ingredient cross-check log against the UK Annexes

Complete SCPN Notification

Before placing on the UK market, every personal care product must be notified via the Submit Cosmetic Product Notification (SCPN) system operated by OPSS. This fully replaces the EU CPNP notification and requires a separate process.

Estimated time: 1-3 days

Notify every personal care product in the SCPN portal, providing: product category and name, contact details of the UK Responsible Person, frame formulation or exact composition, original packaging photo, and label. The notification must be completed before the first sale on Amazon.co.uk. The SCPN portal is technically and organisationally independent from the EU CPNP — an existing CPNP notification is not automatically carried over.

SCPN registration confirmation

Correctly assign product variants and shadesRequired

Each product variant with a different composition (e.g. different fragrance variants of a deodorant or different SPF levels of a sunscreen) generally requires its own SCPN notification. For purely cosmetic variations with an identical base formula (e.g. pure fragrance variants without changes to safety-relevant components), a shared notification under one frame formulation may be possible.

Adapt Labelling for the UK Market

Ensure the product labelling contains all UK-specific mandatory information in English. English-language labelling is sufficient for the UK market — no additional language is required.

Estimated time: 1-2 weeks

Mandatory information on packaging in EnglishRequired

Display the following mandatory information on the product or packaging: name and address of the UK Responsible Person (must be a British address), nominal content (weight or volume), best-before date or PaO symbol (Period after Opening), full INCI ingredient list, batch/lot number, function of the product (unless evident from presentation), and particular precautions and warnings. Since English-language labelling is sufficient for Great Britain, no separate translation into other languages is required.

Updated packaging layouts with UK labelling

Account for UKCA/CE Transition

For personal care products in the narrower sense (pure cosmetics), UKCA or CE marking on the product itself is generally not required, since the UK Cosmetics Regulation provides its own conformity system via the CPSR and SCPN notification. However, if your range includes adjacent products with a different intended purpose (e.g. applicators with electrical components such as electric razors or toothbrushes), the general UKCA marking obligation applies to those items. CE marking continues to be accepted for the GB market on a transitional basis until 31 December 2027.

Meet Amazon.co.uk-Specific Compliance Requirements

Ensure your personal care listing on Amazon.co.uk meets all platform-specific requirements and that the necessary documents are stored in Seller Central.

Estimated time: 3-7 days

Register the UK Responsible Person with a full British address in Amazon Seller Central. Amazon increasingly requires this for personal care products and may deactivate listings or block new listings without this information.

Keep CPSR and SCPN Confirmation Ready for Amazon ComplianceRequired

Keep the complete CPSR, the SCPN registration confirmation, and any further safety data (e.g. SPF test reports or microbiological test reports) readily available. Amazon.co.uk may request these documents at any time, particularly following customer complaints, safety reports, or compliance spot checks.

CPSR, SCPN confirmation, supplementary safety data sheets

Establish Cosmetovigilance and Ongoing Market Surveillance

Set up processes for reporting serious undesirable effects and for ongoing review of your UK compliance. OPSS and Trading Standards conduct continuous market surveillance, including online on Amazon.co.uk.

Estimated time: Ongoing

Set Up Cosmetovigilance System for Serious Undesirable EffectsRequired

Implement a system for recording customer complaints and health reactions (e.g. skin irritation from deodorants, allergic reactions to intimate care products). The UK Responsible Person is legally obliged to report serious undesirable effects to OPSS without delay.

Standard operating procedure for cosmetovigilance reporting to OPSS

Conduct Annual Compliance ReviewRequired

Review annually: currency of the CPSR following formulation changes, validity of the SCPN notification, changes to the UK Annexes for prohibited/restricted substances, continuation of the UK RP agreement, and the status of the UKCA/CE transition for adjacent products. Post-Brexit divergence between UK and EU regulations tends to increase over time.

Annual compliance review report with update log

Common Mistakes to Avoid

Assuming the EU GPSR or an EU CPNP notification is sufficient for the UK market

Consequence: The UK did not adopt the EU GPSR (Regulation 2023/988) after Brexit. An EU CPNP notification has no validity in the UK. Products without a separate SCPN notification and without compliance with GPSR UK 2005 are sold illegally on the British market. OPSS can impose fines and prohibit sales.

Prevention: Treat the UK market as a standalone regulatory regime. Carry out a separate SCPN notification for each product and ensure GPSR UK 2005 compliance independently of your EU compliance.

Not appointing a separate UK Responsible Person or only listing an EU Authorised Representative

Consequence: A product without a UK Responsible Person with a British address may not be sold on the Great Britain market. OPSS can have the product withdrawn from the market, and Amazon.co.uk typically suspends affected listings immediately.

Prevention: Appoint a standalone, UK-based UK RP before entering the UK market and provide their British contact details on the product, packaging, and in the Amazon listing.

Ingredients checked only against EU lists, not the UK-specific Annexes

Consequence: The UK Annexes for prohibited and restricted substances have been decoupled from the EU lists since Brexit and are increasingly diverging, particularly for UV filters in sunscreen products and preservatives. A substance permitted in the EU may be prohibited in the UK — selling it is then a criminal offence.

Prevention: Have your safety assessor check the UK Annexes separately and document the cross-check for each product, particularly for sunscreen and preservative-relevant formulations.

SCPN notification for product variants (fragrance, SPF) incomplete or missing

Consequence: If a variant with a different composition (e.g. a different SPF level or different preservation system) is not notified separately, it is considered unnotified and may not be sold. This leads to OPSS complaints and Amazon listing suspensions.

Prevention: For each product variant, check whether a separate SCPN notification or a shared notification under one frame formulation is permissible, and document this in a traceable way.

Frequently Asked Questions

Q1Does the EU GPSR (2023/988) also apply in the UK?

No. The United Kingdom did not adopt the EU GPSR after Brexit. The UK continues to apply the General Product Safety Regulations 2005 (SI 2005/1803) as its general product safety law, supplemented by the Consumer Protection Act 1987. For personal care products, the UK Cosmetics Regulation additionally applies. Sellers active in both the EU and the UK must comply with two separate regulatory frameworks.

Q2What is the difference between CPNP and SCPN?

CPNP (Cosmetic Products Notification Portal) is the EU system for notifying cosmetic products. SCPN (Submit Cosmetic Product Notification) is the standalone British equivalent, operated by OPSS. Both systems are technically and legally independent of one another — a CPNP notification does not replace an SCPN notification and vice versa. Sellers active in both markets must notify each product separately in both portals.

Q3Do I need UKCA marking for personal care products?

Generally not. Pure cosmetics such as toothpaste, deodorant, or soap are not regulated via UKCA marking, but through the UK Cosmetics Regulation's own conformity system (CPSR plus SCPN notification). UKCA becomes relevant if your range includes adjacent products with electrical or mechanical components, such as electric razors or electric toothbrushes. For such products, CE marking continues to be accepted on a transitional basis until the end of 2027.

Q4Is English-language labelling sufficient for selling on Amazon.co.uk?

Yes. Unlike many EU countries, exclusively English-language labelling is sufficient for the UK market. There is no legal requirement to include additional languages such as Welsh, except in specific contexts not relevant here. What matters is that all mandatory information (ingredients, warnings, UK RP address, shelf life) is present, complete, and correct in English.

Q5How can SpaceGoats help with UK compliance for personal care products?

SpaceGoats supports brands as an Amazon full-service partner throughout the entire UK compliance journey for personal care products: from clarifying your economic operator role, through connecting you with UK Responsible Persons and qualified safety assessors, to SCPN notification and correctly submitting all documents in Amazon Seller Central. Our team knows the specific Amazon.co.uk requirements for the personal care category and can significantly speed up the path to market approval.

GPSR (General Product Safety Regulation)Personal CareUnited Kingdom 🇬🇧