Brexit: What will happen with cosmetic products?

In March 2017, the government of the United Kingdom (UK) submitted the notification of its intention to withdraw from the European Union (EU). Following that, the so called Brexit will become official on 30 March 2019 (“withdrawal date”). Notwithstanding continuous discussions about the conditions of a “hard” or “soft” Brexit, as from the withdrawal date the UK will be considered as “third country” where the EU legislation no longer applies.

Although the media presentation is dominated by political dispute, preparing for the Brexit is not just a matter for the UK and EU governments but also for private parties. In particular, manufacturers and distributors of cosmetic products located in the UK as well as EU based importers of UK products will face massive legal repercussions as soon as Brexit becomes reality.

As from the withdrawal date, manufacturers and distributors of cosmetic products established in the UK will no longer be recognized as “Responsible Persons” in accordance with the European Cosmetics Regulation. Therefore, UK-based companies must ensure in a timely manner that they have a Responsible Person designated within the EU.

Importers on the other side are considered as the economic operators who place cosmetic products from a third country onto the EU market. Therefore, EU-based distributors with UK products in their portfolio must be aware that they will automatically become Responsible Person for these products if there is no other EU-based party designated and their level of responsibility will strongly increase.



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