REGULATORY BREXIT REVIEW
BREXIT SIX MONTHS ON
D
espite having officially left the European Union 18 months ago, it is only in the past six that the true effects
of the UK’s withdrawal have been felt. Indeed, once the transition period ended, it became clear that a large part of the cosmetics and personal care industry in both the UK and EU was ill prepared for the post-Brexit regulatory requirements. You might question why these brands and manufacturers did not take steps to get ready. After all, following the emphatic vote to ‘get Brexit done’ in the December 2019 General Election, the UK’s exit seemed assured. However, the negotiations and transition period were very uncertain throughout, and despite the
44 June 2021
Six months after the transition period expired, Alex Fotheringham reflects on the regulatory changes and the issues that have arisen
as a result of the UK’s exit from the European Union Government announcing plans and timelines, many remained unconvinced that anything would actually happen. Thankfully, there were no surprises in the implementation of the changes and in fact, everything that did change was known well in advance (at least a year). This provided ample time to prepare and those who did so have benefitted over the past six months.
REGULATORY CHANGES Responsible Person (RP) One of the biggest post-Brexit changes for the beauty and personal care industry relates to the Responsible Person (RP). Products sold in the UK and the EU are now subject to two different RP requirements: EU and UK RP.
From 1 January 2021, all UK-based RPs became invalid in the EU. This has left businesses that did not arrange a legitimate alternative in time in a precarious position, with their EU importers taking on the role. This means the importer has the associated liabilities and can now request significant amounts of, potentially confidential, data to undertake its duties. The RP is responsible for ensuring the product is safe for use and must be able to discuss technical and safety issues with the relevant Competent Authority. This requires access to potentially sensitive information. Worryingly, importers are often not even aware of their newly appointed responsibilities until they are inspected
cosmeticsbusiness.com
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