Key differences
- Separate notification systems.
- Separate Responsible Person requirement.
- No automatic mutual recognition.
- Separate documentation expectations.
- Labels and market data must match the relevant jurisdiction.
EU vs UK
Cosmetics compliance: EU, Great Britain and Northern Ireland
The European Union and Great Britain use separate notification systems and Responsible Person arrangements. Products must be assessed for the intended market before placement.
| Requirement | European Union | Great Britain | Northern Ireland |
|---|---|---|---|
| Notification route | CPNP | SCPN | CPNP under the EU cosmetics framework |
| Responsible Person establishment | EU-established | UK-established | Established in Northern Ireland or the EU |
| Territory | EU Member States | England, Scotland and Wales | Northern Ireland |
| Before market placement | Applicable EU safety, file, label and notification requirements | Applicable GB safety, file, label and notification requirements | Applicable EU requirements with the NI arrangements checked |
Practical implications
- EU-only market: EU RP + CPNP.
- Great Britain only: UK-established RP and SCPN notification.
- EU and Great Britain: assess both markets, notification routes and RP arrangements.
Recommended workflow
Start with the exact formula, label and supply route. Identify EU, Great Britain and Northern Ireland requirements before finalising the technical file, Responsible Person details and notifications.
Request assessment
Prepare your product data for review
Send the INCI or formulation, product type, intended market, label artwork where available, and raw-material information where available.
Plan around the legal entity and the product
AsCo Europe’s EU work and any Great Britain appointment must identify the responsible legal entity for the relevant products. A commercial relationship or website link does not appoint an RP. Importers may have RP duties by default; a substitute appointment must follow the applicable written-mandate requirements.
See the official Great Britain guidance and EU Cosmetics Regulation.