36 REGULATIONS
Preparing for the end of Brexit transition period
n Angela Davies – MSL Solution Providers, UK
Since the infamous UK referendum in June 2016, there have been many question marks over Brexit. As deadlines for the United Kingdom’s exit from the European Union came and went without agreements in place, the €78bn EU cosmetics and personal care industry were left confused about what measures needed to be put in place, and the time limits for these to be implemented. But, following the emphatic vote to ‘get
Brexit done’ in the general election in December last year, there was finally some clarity. The UK subsequently made its official exit from the EU on 31 January 2020. More than 500 SME manufacturers and
an unknown number of brands make up the €11.1bn cosmetic and personal care industry in the UK.1
These companies,
alongside thousands more in the European union, now need to take urgent action, so that they are prepared for the changes that come into force when the transition phase expires.
PERSONAL CARE GLOBAL
When will things change? The transition period is due to officially end on 31 December 2020. Until then, even though the UK is no longer part of the EU, existing EU legislation is still in place in the UK. This means that cosmetic products are still covered by the Cosmetic Regulation 1223. The idea behind the transition period is
to give some breathing space to allow new UK-EU negotiations to take place. However, as the UK withdrew from the EU, another huge force was tearing through Europe, and indeed, the whole world. Governments across the world turned their focus to tackling the COVID-19 crisis, meaning that important Brexit negotiations were disrupted. At the same time, many companies have
needed to deal with the immediate crises that the pandemic threw their way, such as huge fluctuations in supply and demand, furlough, and general health issues among staff and their families. Under these extraordinary circumstances, they may have
taken their eye off the ‘Brexit ball’, leaving them in an extremely vulnerable situation as the transition period edges ever nearer. While the transition period could have
been lengthened, the deadline to request an extension has now passed. It is therefore vitally important that companies prepare for the UK to be outside of the EU regulatory framework by the end of December 2020, and for compliance with a future UK regulation to be required next year.
What are the key implications? Cosmetics sold in the UK and EU are currently subject to the European Cosmetic Regulation EC 1223/2009. As of 1 January 2021, new UK legislation will replace the existing EU Regulation within the UK. As with all new UK legislation intended to replace existing EU regulations, this will initially be closely aligned with the EU text with amendments to ensure the text makes sense in the new environment (e.g. changing “Community” to “United Kingdom”). While changes such as these
August 2020
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