What does this mean for your EU and UK cosmetics compliance and of course sales of your cosmetic products? Initially, nothing changes. After Brexit, there will be a transitional period when the EU and the UK will try to agree on the future trade relations, and that transitional period will last till the end of the year (although it will quite likely be extended by another year or 2). Till the end of the transitional period, the CPNP notifications and the EU RP are still valid for the UK as well, and the UK RPs can still act as the EU RPs.

After the transitional period ends though, you’ll need to get a UK based responsible person, do the UK product notification and make some changes on the labels, specifically:
– add the UK responsible person name and address
– since the UK will become a third country, products produced there and sold in the EU, will need to state “made in the UK” and vice versa for the products made in the EU

What are the timelines to appoint the UK RP, make the UK notification and update the labels?
– UK RP will have to be appointed at least till the end of the transitional period
– UK notification will have to be done in up to 3 months after the end of the transitional period
– Labels will have to be updated in up to 2 years from Brexit

Besides that, the cosmetics legislation in the EU and in the UK will remain the same for now. Future changes in the legislation may happen though.

CE.way has set up a subsidiary in the UK last year, so we can provide also the UK RP service and can do UK product notifications (once the UK notification portal becomes operational, at the moment it doesn’t exist yet). Contact us to get an offer if you’re interested in these services.

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Since June 2014, the start of Project LARGO, Switzerland introduced many changes to its regulation. The main aim was to harmonize Swiss regulation with European Union (EU) and by doing so, opening the market, upholding bilateral treaties as well as ensuring a high level of consumers’ safety.

In addition to updates on the Ordinance on foodstuffs and consumer products, there were also updated requirements regarding cosmetic products. These updates include:

• compliance with the lists of regulated substances,
• the labelling,
• the obligation to keep product information file (PIF),
• compliance with GMP,
• the ban on animal testing.

These ordinances, including the Ordinance on cosmetic products, entered into force on May 1^st, 2017. Nevertheless, they are subject to the following transitional periods:

• Appointment of responsible person (RP) and animal testing: 1^st of May 2018,
• Lists of regulated ingredients: 31^st of December 2018,
• PIF redaction and GMP compliance: 30^th of April 2021.

Regarding cosmetic claims, Switzerland now follows the six criteria from the EU regulation: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making.

Despite harmonization, there are still some remaining differences between the Swiss and EU regulation that need to be noted:

• A manufacturer or importer must be designated to each cosmetic product placed on the Swiss market. This person is responsible for ensuring compliance with the Swiss regulation, but they may delegate their obligation to an agent who is located in Switzerland.
• It is possible to put the address of the EU RP on the packaging of a cosmetic product but the obligation of ensuring compliance with the Swiss regulation remains with manufacturer or importer and may not be delegated to that EU RP or any other person abroad.
• Every cosmetic product needs to have a complete PIF except for artisanal cosmetics sold locally that are not intended for children.
• If a cosmetic product was already placed on the market abroad, the importer/manufacturer must provide proof that a PIF on the product is already established and compliant with the Swiss regulation, without the need to present the PIF to the authorities.

If you wish to ensure that your products are compliant with the Swiss regulation and EU Cosmetic regulation, don’t hesitate to contact us. We will help you with regulatory questions and keep you up to date with the latest regulatory developments.

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