UK Responsible Person and SCPN: Selling Cosmetics in Great Britain

Does Great Britain need a UK Responsible Person and SCPN?

Yes to both. A cosmetic may not be placed on the market in Great Britain without a Responsible Person established in the UK, and that person notifies it.

The EU rule and the Great Britain rule are separate. Article 4(1) of Regulation (EC) No 1223/2009 asks for a Responsible Person designated within the EU. The Great Britain version, substituted by paragraph 5 of Schedule 34, asks for one established in the UK. The GOV.UK guidance adds that a UK established address is needed.

A seller based outside the EU therefore needs an EU Responsible Person for the EU and a UK one for Great Britain. A Responsible Person established only in the EU does not satisfy a rule that asks for one established in the UK. Whether an EU safety report can be used in Great Britain is a separate question. The guide to where a CPSR is valid covers it, and the guide for Amazon sellers on the UK Responsible Person gives the marketplace view.

What is SCPN, and who submits it?

SCPN is the UK electronic notification. The Responsible Person submits it before the product is placed on the market in Great Britain.

Paragraph 13 of Schedule 34 substitutes Article 13 for Great Britain. Under it, the Responsible Person notifies electronically before placing the product on the market. The GOV.UK guidance describes it as submitting information before a cosmetic product is made available in Great Britain. It is done through the Submit cosmetic product notifications service.

The EU's CPNP is a different system, the Commission's free online notification system for the EU. The EU and UK notifications are separate filings, and each is made by the Responsible Person for that market. A brand selling in both markets needs a notification in each. The step is a duty of the role, not a task for the marketplace or the laboratory. The UK notification is not in the per-formula fee. The appointment comes first, because the notification is the Responsible Person's duty.

What does the UK Responsible Person keep?

In Great Britain the Responsible Person keeps a PIF in English, and the PIF includes the product safety report. The Responsible Person also needs a UK established address.

The GOV.UK guidance sets out both points. The English-language rule matters for a brand that holds its documents in another language. The UK address is part of the role. The Responsible Person's place of establishment, the PIF and the notification all sit with one UK-established person. The product safety report sits inside the PIF.

The EU position is similar in shape. Under Article 11, the Responsible Person keeps the PIF for ten years after the last batch. Among other items, the PIF holds the CPSR, the manufacturing method, a GMP statement and data on any animal testing. Under Article 10(1), a safety assessment and a CPSR must exist before the product is placed on the EU market. These EU duties and the Great Britain duties sit in separate legal texts, and each market needs its own Responsible Person.

What does the Eldris UK Responsible Person service cover?

Eldris can be the UK Responsible Person as a separate appointment, at the same market fee as the EU one, under the same monthly plan.

The UK appointment is not part of the per-formula fee for the CPSR and PIF. That fee excludes Great Britain, the UK Responsible Person and the UK notification. The market fee is paid once for each market. The market fee and the monthly plan are on the pricing page. A discount applies to the market fees only, not to the monthly plan.

One appointment per country covers every product type, so adding a product type does not mean a new appointment. The monthly plan is set by the number of SKUs, and one plan covers the EU and UK appointments. The plan can be cancelled at any time, effective at the end of the billing period, and the appointment then ends. The CPNP notification and CPSR service is a different service from the role.

Which Responsible Person does each market need?

The EU asks for a Responsible Person designated within the EU, and Great Britain for one established in the UK. Northern Ireland is a separate case.

For Northern Ireland, the GOV.UK guidance says the Responsible Person must be established in Northern Ireland or the EU. The Great Britain guidance does not cover Northern Ireland, so placing a product on the market there is a different matter from Great Britain. The notification follows the same split: the CPNP for the EU and SCPN for Great Britain.

A seller who sells in the EU and in Great Britain therefore needs a Responsible Person for each. Eldris can take both as separate appointments under one monthly plan, each with its own market fee. A business established in the EU can hold the EU role itself. Check where each product is placed on the market before choosing the appointments. The same answer is in the FAQ on the UK Responsible Person and SCPN.

Frequently asked questions

Which comes first, the UK Responsible Person or the notification?

The Responsible Person. Under Schedule 34, the Responsible Person submits the notification before the product is placed on the market. A cosmetic may not be placed on the market in Great Britain without a UK Responsible Person at all. The appointment therefore has to be in place first.

Do I pay a second monthly plan for Great Britain?

No. The UK appointment is covered by the same monthly plan as the EU one, and the plan is set by the number of SKUs. The UK appointment has its own market fee, at the same level as the EU one. The figures are on the pricing page.

Is Great Britain included in the per-formula fee?

No. The per-formula fee includes the signed CPSR and the PIF for one formula, paid once. The UK Responsible Person, the UK notification and laboratory tests are outside it. The EU notification is outside it too. The Responsible Person's fees are on the pricing page.

Is the UK notification made in the CPNP?

No. The CPNP is the Commission's free online notification system for the EU. Great Britain uses SCPN, the UK electronic notification, made by the UK Responsible Person. A brand selling in both markets needs a notification in each. The UK notification is not in the per-formula fee.

Does one UK appointment cover every product type?

Yes. One appointment per country covers every product type, so adding a product type does not mean a new appointment. The UK appointment is separate from the EU one, and the same monthly plan covers both. The plan is set by the number of SKUs.

Can the Great Britain appointment be cancelled?

The Responsible Person service can be cancelled at any time, effective at the end of the billing period. The appointment then ends. Eldris's details must come off labels and listings within 30 days, so plan the change before the billing period closes. The cosmetics service has no monthly fee.

Can I use my EU Responsible Person for Great Britain?

Only if that person is also established in the UK. Great Britain asks for a Responsible Person established in the UK, so a Responsible Person established only in the EU does not meet the rule. Eldris offers the UK role as a separate appointment.