Halden The 31 December 2027 label deadline: what EU brands need to do
Since Brexit, a cosmetic product sold in Great Britain needs a UK Responsible Person, and the label normally has to show that person's name and address. There is one temporary exception that matters a lot to EU brands: a product labelled with its EU Responsible Person can still be sold in Great Britain without UK details on the pack. That exception ends on 31 December 2027.
It is easy to read this as "we don't need a UK Responsible Person until 2028". That is not what it says.
What the rule actually says
The exception sits in Article 19(1)(ab) of Regulation (EC) 1223/2009 as it applies in Great Britain. It was inserted by the Brexit legislation (SI 2019/696) as a two-year rule, and the Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393) changed "two years" to "seven years", counted from the day after the end of the Brexit transition period on 31 December 2020. Seven years from 1 January 2021 ends on 31 December 2027. The Office for Product Safety and Standards (OPSS) states that date in its guidance for Great Britain.
During that period, the label requirements for the Responsible Person's name and address (and country of origin) are treated as met if the label meets the equivalent EU requirements, which means showing an EU Responsible Person.
What it does not cover
- You still need a UK Responsible Person now. Article 4(1) says a cosmetic product may not be placed on the market unless there is a Responsible Person established in the UK. The exception changes what goes on the label, not who must exist.
- You still need an SCPN notification now. Article 13 requires the Responsible Person to notify each product before it is placed on the market. In Great Britain that is done on the Submit Cosmetic Product Notifications service (SCPN). An EU CPNP notification does not count.
- It does not cover Northern Ireland. SI 2022/1393 extends to England and Wales and Scotland. Northern Ireland follows EU rules and needs a Responsible Person in Northern Ireland or the EU.
- It does not cover labels with no Responsible Person on them. It works only where the pack already shows an EU Responsible Person and meets the EU rules.
If you sell into Great Britain today with no UK Responsible Person and no SCPN notification, the 2027 date does not help you. That needs fixing now.
What happens on 1 January 2028
Article 19(1) is written in terms of when products are "made available on the market", not only when they were first placed on it. Business Companion, the Trading Standards guidance site, says that after the deadline the EU Responsible Person's details "must be replaced by those of the UK responsible person".
We have not found any official sell-through period for stock already on the market on 1 January 2028. Our reading, which is an interpretation rather than official guidance, is that from that date a pack showing only an EU Responsible Person should not be made available in Great Britain, even if it was shipped into the UK earlier. If a lot of your stock sits in UK warehouses or marketplace fulfilment centres, plan for that.
What to do now
- Check you have a UK Responsible Person and SCPN notifications in place. If you sell in Great Britain and do not, that is the first job, not a 2027 job.
- Put the UK Responsible Person on your next print run. Article 19(1)(a) allows a label to carry more than one address, as long as the one where the product information file is kept is highlighted. Our reading, which is an interpretation rather than official guidance, is that one pack can show both your EU and your UK Responsible Person, with the UK one highlighted for Great Britain.
- Count your stock against the date. Work out how much EU-only stock you will still hold in Great Britain, including at Amazon or other fulfilment centres, by late 2027, and plan to sell it through or relabel it before the end of December 2027.
- Ask your UK Responsible Person before you over-label. We found no official guidance specifically on using stickers to add UK Responsible Person details. The general rule is that label information must be indelible, easily legible and visible on both the container and the outer packaging. Bear in mind that a distributor who relabels a product in a way that could affect compliance with the rules can itself become the Responsible Person under Article 4(8).
- Watch for changes. We found no sign of a further extension or a permanent change as of October 2026. If the date moves, it will be by a new statutory instrument, and we will cover it on this page.
A note on older GOV.UK pages
Some older GOV.UK pages, such as the 2020 page "Submit a cosmetic product notification", still say UK Responsible Person details were required on packaging from 31 December 2022. That was the date before the 2022 extension. The legislation and the current OPSS guidance both give 31 December 2027.
How we help
We act as UK Responsible Person for EU brands selling into Great Britain. During the transition, where we agree it in your product schedule, products already labelled with your EU Responsible Person and meeting EU rules can carry on as they are, while we hold the UK file and the SCPN notification. Your next artwork carries our details. Our prices are published, and our free label check gives you a quick first look at what on your pack may need changing for Great Britain.
Common questions
Do I need a UK Responsible Person before 2028?
Yes. If you sell cosmetics in Great Britain, you need a UK Responsible Person and an SCPN notification for each product now. The 2027 date only affects what goes on the label.
Can I sell old stock with only the EU Responsible Person after 31 December 2027?
We found no official sell-through period. Our reading, which is an interpretation, is that from 1 January 2028 a pack showing only an EU Responsible Person should not be made available in Great Britain.
Can my label show both my EU and UK Responsible Person?
Article 19(1)(a) allows more than one address as long as the one where the product information file is kept is highlighted. Our reading is that a pack can show both, with the UK one highlighted for Great Britain.
Has the deadline been extended again?
Not that we have found. As of 16 October 2026 the legislation still says seven years, and we found no sign of a further extension. Any change would come through a new statutory instrument.
Read next: How to switch your UK Responsible Person
Sources
- Regulation (EC) 1223/2009 as it applies in GB, Article 19: legislation.gov.uk/eur/2009/1223/article/19
- Article 4: legislation.gov.uk/eur/2009/1223/article/4 and Article 13: legislation.gov.uk/eur/2009/1223/article/13
- SI 2019/696, Schedule 34 (the original two-year rule): legislation.gov.uk/uksi/2019/696/schedule/34
- SI 2022/1393, regulation 7 (the extension to seven years): legislation.gov.uk/uksi/2022/1393/regulation/7/made
- OPSS guidance for Great Britain: gov.uk, Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (Great Britain)
- Older GOV.UK page (last updated 31 December 2020): gov.uk/guidance/submit-a-cosmetic-product-notification
- Business Companion, cosmetic products: businesscompanion.info
This post is general information, not legal advice. It reflects the legislation and guidance as we found them on 16 October 2026.