Importing cosmetics from the UK – UK Cosmetics Regulation, labelling and compliance

Importing cosmetics from the United Kingdom to Poland and other EU member states after Brexit is a topic that trips up even experienced importers. UK cosmetics manufacturers must now comply with two independent regulatory systems: the British UK Cosmetics Regulation (based on UK Regulation 1223/2009 — an analogue of the EU version, but administered independently by the Office for Product Safety & Standards) and the EU Cosmetics Regulation 1223/2009. Every consignment of cosmetics entering the Polish market must have an appointed Responsible Person (RP) established in the EU, a notification filed in the CPNP (Cosmetic Products Notification Portal), labels that comply with EU requirements (including in the Polish language), and a formula that meets the EU lists of prohibited and restricted substances. Mistakes in this area can result in goods being held at the border, a market withdrawal order issued by the trade inspection authority, or significant administrative fines. This article walks you through every step: from compliance verification to CPNP notification and labelling, through to customs clearance.

UK Cosmetics Regulation vs EU Cosmetics Regulation — what changed after Brexit?

Before Brexit, the UK applied EU Regulation (EC) No 1223/2009 without modification. After 1 January 2021 the UK adopted its own version of that regulation — UK Regulation 1223/2009 — administered by OPSS (Office for Product Safety & Standards). Both pieces of legislation are broadly aligned, but there are important differences:

Aspect	UK (from 2021)	EU (including Poland)
Legislation	UK Cosmetics Regulation (UK SI 2019/696)	EU Cosmetics Regulation 1223/2009
Regulator	OPSS (Office for Product Safety & Standards)	Relevant national authorities (in PL: GIS)
Notification	SCPN (Submit Cosmetic Product Notification) — new UK system	CPNP (Cosmetic Products Notification Portal) EU
Responsible Person	Must be established in the UK	Must be established in the EU
Substance lists	Gradually diverging from the EU	Annex II, III, IV, V, VI EU
Labels	In English (or Welsh for Wales)	In the official language of the destination country

Key takeaway for importers: a cosmetic notified in the UK SCPN is not automatically notified in the EU CPNP. To sell a cosmetic from the UK in Poland, the manufacturer or importer must make a separate notification in the CPNP and appoint a Responsible Person in the EU.

CPNP — mandatory notification before placing on the market

The CPNP (Cosmetic Products Notification Portal) is the European Commission's portal through which the Responsible Person must register every cosmetic product before it is placed on the EU market. Notification is free of charge and carried out online.

What information must be provided in the CPNP?

1. Product name — trade name and chemical (INCI) name
2. Product category — shampoo, cream, nail varnish, etc.
3. Responsible Person — details of the responsible entity in the EU
4. Ingredient list (INCI) — complete list with CAS numbers
5. Composition frame — nanomaterial ingredients require a separate notification
6. Packaging (graphic or photograph)
7. Country/countries of market placement
8. Contact details for medical services (emergency contact)

The notification must be made before the product is first placed on the EU market. Placing a product on the market without notification is an administrative offence and may result in a withdrawal order.

Responsible Person (RP) — who they are and why they are essential

The Responsible Person is a legal or natural person established in the EU who takes full responsibility for the cosmetic product's compliance with the EU Cosmetics Regulation. Without an RP established in the EU, the product cannot legally enter the EU market.

Who can act as RP?

• The manufacturer — if established in the EU (after Brexit this applies to EU manufacturers, not those in the UK)
• The importer — if importing a cosmetic from a third country (including the UK) for distribution in the EU
• A distributor — may voluntarily assume the RP role
• A designated third-party entity — a UK manufacturer may appoint an EU-based company as RP (RP outsourcing service)

An importer of cosmetics from the UK to Poland automatically becomes the Responsible Person for the products they import, unless the UK manufacturer has designated another entity in the EU as RP. The RP role carries the following obligations:

1. Retaining the Product Information File (PIF) for 10 years
2. Reporting Serious Adverse Events (SAEs) to the relevant authority
3. Ensuring access to information for control authorities
4. Monitoring changes to EU substance lists

Labelling of cosmetics imported from the UK — obligations in Poland

Every cosmetic sold in Poland must bear a label that complies with the EU Cosmetics Regulation and the Polish Cosmetics Act. For products imported from the UK this typically means the need to translate or supplement the labels.

What must appear on the label?

Mandatory element	Notes
Name and address of the Responsible Person in the EU	Must be EU-based — a UK manufacturer's address is insufficient
Country of origin	Mandatory for products originating outside the EU
Nominal content (weight/volume)	In grams or millilitres
Minimum durability date or period after opening	Hourglass symbol or PAO (open jar symbol)
Special precautions	Arising from the formula
Batch number	Traceability
Function	If not apparent from the product's appearance
Ingredient list (INCI)	In descending order of concentration, preceded by the word "Ingredients:"
Ingredient warnings	E.g. "Contains: linalool" for fragrance allergens

Label language: all of the above information must be provided in Polish (or in another language comprehensible to the Polish consumer). It is sufficient to affix a Polish-language sticker over the original packaging, provided it covers or supplements all mandatory elements.

Prohibited and restricted substances — UK vs EU differences

Since Brexit, the lists of permitted and prohibited substances in the UK and the EU have been gradually diverging. This is important when importing cosmetics: a substance permitted in the UK may be prohibited in the EU and vice versa.

Key differences (as at 2026)

Substance	Status in UK	Status in EU	Notes
Certain UV filters (e.g. avobenzone)	Permitted	Restricted	EU applies stricter limits
Formaldehyde and donors	Different limits	Prohibited above 0.1%	EU stricter since 2023
Certain preservatives (MIT)	Permitted in rinse-off products	Prohibited or limited	Different restrictions apply
Thiourea	Restricted	Prohibited	UK has not updated its position

Practical tip: before importing a new line of cosmetics from the UK, always commission a composition review by a cosmetic chemist or a lawyer specialising in EU cosmetics law. An error can cost more than the entire consignment.

Customs clearance of cosmetics from the UK — HS codes, duty and VAT

Cosmetics imported from the UK are subject to the standard import customs procedure. Key information is set out below:

HS codes for cosmetics

Type of cosmetic	HS code
Cleansing preparations — shampoos, gels	3305, 3304
Face and body creams, lotions	3304.99
Perfumes and toilet waters	3303
Make-up preparations	3304.10–3304.91
Oral hygiene preparations	3306
Nail varnishes	3304.30
Hair preparations	3305
Soaps	3401

Duty rates and VAT

Scenario	Duty rate	VAT (PL)
Cosmetics manufactured in the UK (TCA)	0–6.5% (depends on HS code; most attract 0%)	23%
Cosmetics from the UK not meeting rules of origin	Up to 6.5%	23%
Perfumes	0% (TCA)	23%

The cost of import customs clearance for cosmetics: £45–150 per declaration, depending on the number of lines and the value of the consignment.

The figures quoted are indicative — an exact quote will be provided once documents are submitted.

Common mistakes when importing cosmetics from the UK

1. No Responsible Person in the EU — the UK manufacturer has not appointed an RP and the importer is unaware that they automatically become one
2. No CPNP notification — notification solely in the UK SCPN does not authorise sale in the EU
3. Labels in English only — selling in Poland requires labels in Polish
4. Outdated ingredient list — the formula changed by the manufacturer without updating the CPNP notification
5. No PIF (Product Information File) — the RP must retain complete product safety documentation
6. No safety assessment — every cosmetic must have a Safety Assessment signed by a suitably qualified person