What impact will anti-deforestation regulation have on the cosmetics industry?
20 June 2025
Since leaving the EU, the United Kingdom has implemented its own regulatory framework, resulting in significant differences from European regulations.
CLEAR provides an overview of the main differences to date.
In England, Scotland and Wales, cosmetics are now regulated by the UK Cosmetics Regulation (The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 – Schedule 34), while Northern Ireland remains unaffected.
The Office for Product Safety and Standards (OPSS) is the competent authority responsible for regulating and verifying the compliance of cosmetic products on the market.
EVOLUTION OF THE UK COSMETICS REGULATION
On 1 January 2021, the United Kingdom established its own independent scientific body responsible for reviewing cosmetic ingredients: the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS). This body has taken over the functions of the Scientific Committee on Consumer Safety (SCCS) in the EU.
An important consequence of this is that the United Kingdom will not automatically incorporate European changes into its own annexes until they have been evaluated by this body.
Following Brexit, changes to UK regulations primarily involved applying new EU regulatory restrictions on a deferred basis.
However, the United Kingdom recently introduced restrictions on substances such as methyl salicylate, BHT and 12 additional CMR substances that differ from those of the EU.
Progress also remains very slow. Examples include:
- the 56 additional allergens that are restricted in the EU, but which are not currently regulated in the UK;
- and the hot topic of PFAS substances, which is not considered a priority by the British authorities.
It is therefore important to remain vigilant and regularly check for new restrictions to come.
LABELLING
The British government has extended the deadline for labelling compliance to 31 December 2027. This specifically includes the requirements to state ‘Made in’ (products bearing only ‘Made in EU’ will not comply), provide the address of the Responsible Person in the UK, and display the UKCA marking on aerosols.
NOTIFICATION
Following Brexit, the United Kingdom established its own notification platform: the Submit cosmetic product notifications (SCPN) platform. No significant changes have been observed since then, except for the addition of more detailed requirements compared to the European cosmetic products notification portal (CPNP) portal (which increases the time required for notifications), and the continued impossibility to modify existing notifications.
ENVIRONMENTAL REGULATIONS
As part of extended producer responsibility (EPR), the UK government has introduced harmonised, mandatory recyclability labelling for primary and transport packaging. It also plans to introduce sorting guidelines, which will most likely be harmonised with those of the Packaging and Packaging Waste Directive 94/62/EC (PPWR).
REACH
UK REACH, which has governed the regulation of chemical substances since the UK left the EU, is based on the same fundamental principles as the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation of the EU. However, the British government has failed to keep pace with developments in European regulations.
A good example of this is the lack of regulatory restrictions on microplastics to date.
The UK authorities have finally committed to introducing appropriate transition periods if regulatory measures are in place which diverge from EU’s REACH regulation.
CONCLUSION
The UK’s regulatory framework is slowly evolving but is clearly moving away from that of the EU. In this uncertain context, it is essential to anticipate future requirements.
The days of a simple EU/UK transposition are over.
CLEAR supports brands in complying with the UK Cosmetics Regulation, including acting as a Responsible Person in the United Kingdom.
Sources:
https://academic.oup.com/ieam/article/20/5/1529/7821737?login=false
https://www.ctpa.org.uk/uk-cosmetic-regulations-amendments
COSMED
FEBEA
The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019
