Portal Notifications (CPNP)
The EU CPNP (Cosmetic Product Notification Portal) intends to deactivate UK portal entities after 31st January 2020. It is imperative that products which have previously been registered on the CPNP with a UK-based RP are changed to an EU-based entity before the exit date, or a full re-notification will be required. After this date, new products will not be able to be registered on the EU Cosmetic Product Notification Portal (CPNP) by a UK-based RP.
It is highly likely that the UK will introduce a similar registration system to the EU CPNP, where every cosmetic product intended to be placed on the UK market must be notified, with the support of a UK-based RP. After Brexit, those:
- Which already have an EU CPNP notification will need to have a notification on the new UK CPNP (within 90 days after 31st January 2020 if there is ‘no deal’)
- Which have not previously been notified on the EU CPNP will require a notification on the new UK CPNP before being placed on the market.
If this is left to the date of withdrawal, then a business has just 90 days to undertake the following:
- Set up a UK legal entity or mandate your UK Responsible Person duties to a UK entity
- Notify all products on the UK CPNP
- Begin to update product packaging labels with the new RP details. It is noted that all labelling must be made compliant with the UK Regulation (including UK RP details) within 2 years after 31st January 2020.