UK SCPN Cosmetics Notification vs EU CPNP Compared

The main difference between UK SCPN cosmetics notification and the EU CPNP is where the responsible person must be based and which portal you use.

To sell in Great Britain (England, Scotland and Wales), a responsible person with a UK address notifies the product through the government’s Submit Cosmetic Product Notifications (SCPN) service. Northern Ireland still follows EU law, so products sold there are notified on the EU CPNP by a responsible person in Northern Ireland or the EU.

If you import Korean cosmetics for both markets, plan for two responsible persons, two notifications and two addresses on the label. The table is based on GOV.UK guidance and the EU Regulation.

UK SCPN vs EU CPNP: comparison table

Swipe sideways to see the whole table.

Responsible person: decide this first

Article 4 of Regulation (EC) 1223/2009¹ requires an EU-based responsible person for products sold in the EU. The UK government’s guidance for Great Britain² says the responsible person must have a UK-established address, and that mail forwarding or PO box addresses do not count. The role can be filled by a company or an individual, including a sole trader.

An EU responsible person alone cannot cover GB sales, and a UK one cannot cover EU sales. Importers selling in both markets usually appoint one in each, or use a service provider with entities on both sides.

Notification portals and what they ask for

In the EU, one CPNP³ notification covers all Member States. In GB, you use the SCPN service⁴, which asks for the product category and name, the responsible person, where the PIF is kept, an urgent contact, any nanomaterials or CMR substances, a summary of ingredients, and images of the label and packaging.

SCPN search is restricted to competent authorities, mainly Trading Standards and the National Poisons Information Service.

Labels and the product information file

The label content is almost the same in both markets: the responsible person’s name and address, country of origin for imports, nominal content, use-by information, precautions, batch number, function, ingredients and “(nano)” after nanomaterials.

The difference is the address. Many importers print both the EU and UK responsible person addresses on one label so the same stock can serve both markets.

GOV.UK guidance says the GB product information file must be in English and kept for 10 years after the last batch. The EU file is kept at the responsible person’s address for 10 years in a language the authorities can readily understand. See our product information file guide.

Northern Ireland follows the EU route

The UK government’s GB regulation guidance⁵ states that products sold in Northern Ireland must comply with EU law and be notified on the EU CPNP by a responsible person in Northern Ireland or the EEA.

Products sold in both GB and Northern Ireland are notified on both systems. The same guidance notes that the government is seeking a new balance in the Northern Ireland arrangements, so check the latest GOV.UK pages before selling there.

Ingredient rules diverge over time

The GB regulation started as a copy of the EU one, but since Brexit each side amends its ingredient annexes on its own timetable. A substance banned in the EU may be banned in GB later, or on different terms. Check both sets of annexes; our Korea vs EU ingredient restrictions comparison covers the EU side.

Summary

• EU only: EU responsible person and CPNP notification.
• GB only: UK responsible person and SCPN notification.
• Both: two responsible persons, two notifications, both addresses on the label.

SEONGWOO GLOBAL supplies Korean skincare to overseas buyers from Seoul. If you import into the UK or the EU, contact us through the pages below.

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