UK Cosmetics Compliance 2026: SCPN Notification and Post-Brexit Rules for Importing from China

Published: September 7, 2026 | Author: 8OEM Editorial Team | Read time: ~5 minutes

Selling cosmetics in the UK is not the same as selling in the EU — and it is not the same as it was before Brexit. If you manufacture with a Chinese OEM and want to sell in England, Scotland, or Wales, the product must be notified through the UK's SCPN system, not the EU's CPNP. This guide explains the UK route: who notifies, what to prepare, and how to plan it with your factory.

This article is general business guidance, not legal advice. Confirm current requirements with a UK compliance specialist for your specific products.

UK vs EU: the notification split

Since Brexit, the UK operates its own cosmetics regime:

• Great Britain (England, Scotland, Wales) — products must be notified through SCPN (Submit Cosmetic Product Notification), operated by the Health and Safety Executive (HSE).
• Northern Ireland — under the Windsor Framework, cosmetics placed on the NI market are notified through the EU CPNP instead.

If you sell in both GB and NI, you may need both notifications. Check which markets your retail plan actually covers.

The Responsible Person requirement

Like the EU system, UK cosmetics regulation requires a UK-established Responsible Person (RP). The RP:

• Holds the Product Information File (PIF).
• Ensures the product complies with the UK Cosmetics Regulation (UK version of Regulation (EC) No 1223/2009, as retained and amended).
• Submits the SCPN notification.
• Handles adverse event reporting and market surveillance communication.

A Chinese factory cannot be your UK Responsible Person unless it has a UK-established entity. In practice, most brands use a UK compliance service or their importer as the RP. Decide and contract this role before you plan a launch — it is a common bottleneck.

The SCPN notification process

1. Create an account on the SCPN system (operated by HSE) as the Responsible Person or your appointed agent.
2. Prepare product data: brand name, product name, category, formulation (INCI), frame formulation where applicable, packaging details, and the product's intended function.
3. Submit and pay the fee: the UK system charges a notification fee per product (the fee structure changed with the new SCPN portal in 2024 — check the current HSE schedule).
4. Receive the notification number and keep records updated for any formulation or packaging changes.

The 2024 SCPN portal introduced a single online submission system replacing the previous Notification of Cosmetic Products (NCP) service. Fees and thresholds change, so always verify current HSE guidance before a batch of notifications.

What your OEM factory should provide

The factory's job is documentation, not notification. Before your UK launch, ask the factory for:

• Full formulation with INCI names and percentages where required — needed for the SCPN submission.
• Raw material data: allergen declarations, certificates, and safety-relevant information.
• Stability and preservative challenge test reports — inputs to the safety assessment.
• Finished product specifications and batch documentation for the PIF.
• Compliance statements for UK labeling requirements (UK RP address, INCI list, usage instructions, warnings, and the product's manufacturing batch identification).

Labeling requirements for the GB market

UK labels must include:

• The product's name and function.
• INCI ingredient list in descending order of concentration.
• Name and address of the UK Responsible Person.
• Country of origin, batch number, and the period-after-opening (PAO) symbol or expiry date.
• Usage instructions, warnings, and any required regulatory statements (e.g., sun protection claims carry their own rules).
• Allergen labelling for 26 fragrance allergens, per the UK regulation, when present above threshold.

Cosmetics do not generally require a UKCA mark — the mark is for other regulated products. What matters is the RP, the SCPN notification, and compliant labeling.

Planning the UK route with a Chinese factory

• Contract the RP early. Confirm who your UK Responsible Person will be before committing to artwork or production dates.
• Get the compliance deliverables in the manufacturing contract. If your factory "will help with UK compliance" is not written down — what exactly will they provide, and when?
• Budget for the notification fee and compliance service per SKU. Include it in your launch unit economics.
• Keep the PIF current. Any formula change means updating the safety assessment and, where relevant, the SCPN record.

Frequently Asked Questions

Do I need SCPN if I already have EU CPNP?

Yes, for Great Britain. CPNP covers the EU and Northern Ireland; GB uses SCPN. Selling in both requires both notifications (with an EU RP and a UK RP respectively).

Can my Chinese OEM factory be my UK Responsible Person?

Only if it has a UK-established entity with the legal responsibility. In practice, use a UK compliance service or your UK importer.

Is there a fee for SCPN?

Yes — HSE charges a notification fee per product, and the schedule changed with the 2024 portal. Verify current fees before budgeting.

What happens if I sell without SCPN?

Selling non-compliant cosmetics in GB risks enforcement action by the market surveillance authority, including removal from the market.

Conclusion

The UK is a high-value but procedurally distinct market: GB needs SCPN via a UK Responsible Person, NI needs EU CPNP, and labeling must carry the UK RP details. Plan the RP, collect the documentation stack from your factory, and build the notification fee into your costs. Get the paperwork right and the UK route is straightforward — get it wrong and products sit at the border.

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• Free sampling & quotation — How sampling, revisions and approval work before mass production.
• Certifications we hold — ISO 22716, FDA-registered facility, and what each certificate actually covers.
• Japan & Korea Cosmetics Compliance 2026: PMDA, MFDS and Market Entry That Won't Get Blocked