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Guides / EU cosmetics to GB checklist · Updated 30 September 2026

Selling EU cosmetics into Great Britain: a seller's checklist

A practical order of work for Polish and other EU cosmetics brands: who your GB Responsible Person is, when to notify, what the label must show, why Northern Ireland is different, and the customs declarations at both ends.

If you run a cosmetics brand in Poland or elsewhere in the EU, selling into Great Britain is not simply a matter of booking a courier. Product safety law in GB is enforced by the Office for Product Safety and Standards (OPSS), and customs rules apply at both ends of the journey. This checklist sets out the order in which a seller usually tackles the work. For the rules seen from the importer's side, read our companion guide on importing cosmetics into the UK.

Step 1: decide who will be your GB Responsible Person

Every cosmetic product made available to consumers in Great Britain needs a Responsible Person (RP). GOV.UK is clear that the RP must have a UK established address, and that a mail forwarding service or PO box does not count. An EU brand with no UK establishment therefore cannot act as its own RP for the GB market.

The RP can be a manufacturer, an importer, a distributor selling under its own brand, or a person appointed to take on the role. In practice an EU seller has three routes:

Whichever you choose, agree in writing who holds the Product Information File, who submits notifications and who handles reports of serious undesirable effects. Those duties sit with the RP, not with the courier or the customs agent.

Step 2: prepare the safety assessment and product information file

GOV.UK states that a product's safety must be checked by a qualified safety assessor before it is made available to consumers. The RP must also keep a Product Information File (PIF) in English for 10 years after the last batch was manufactured. If your existing EU documentation is in Polish, plan time for translation and for your RP to review it; the RP will be answerable to OPSS if a question arises.

Step 3: notify the product through SCPN before launch

Before a cosmetic product is made available in GB, the Responsible Person must submit information about it to OPSS using the Submit cosmetic product notifications service (SCPN). This is a separate step from any notification you have already made for the EU market; an EU notification does not carry across to GB. Build the notification into your launch plan so that stock does not sit in a UK warehouse waiting for paperwork.

Step 4: relabel with the GB Responsible Person

The container and packaging must show the name and address of the Responsible Person. For an EU brand this usually means a GB-specific label or sticker, because the RP printed on EU stock is established in the EU. GOV.UK also lists the other mandatory particulars, including:

Check each label against the current GOV.UK list rather than an old artwork file; mistakes found after the goods have crossed the border are far more expensive to fix.

Step 5: treat Northern Ireland as a separate case

The OPSS guidance for Great Britain explicitly does not cover Northern Ireland. For products made available in NI, the Responsible Person must be established in Northern Ireland or the EU. That means an EU brand selling into NI may be able to rely on its existing EU arrangements, while stock destined for England, Scotland or Wales needs the GB RP, SCPN notification and GB label described above. If you ship to both, keep the two flows apart in your stock records and confirm the NI position with the relevant authority before you launch.

Common mistake: assuming one set of UK paperwork covers the whole of the UK. Great Britain and Northern Ireland follow different cosmetics rules, so decide early which market each shipment is for.

Step 6: the export declaration in the EU

Goods leaving the EU for Great Britain are exports. Under EU procedure, the exporter or declarant lodges an export declaration electronically through the Automated Export System at the customs office where they are established or where the goods are packed or loaded. That office releases the goods and passes the data to the customs office of exit, which checks the goods and supervises their departure. Keep the evidence of exit with your sales records: your accountant will need it to support the export treatment of the sale.

If your goods move by road through several countries, a transit movement may be used between the office of departure and the border; see our guide to T1 transit for how that works.

Step 7: the UK import declaration

On arrival, someone must make a UK import declaration. GOV.UK sets out the core steps for the importer:

  1. hold an EORI number starting with GB to import into England, Wales or Scotland;
  2. find the correct commodity code, which determines the duty rate and whether a licence is needed;
  3. work out the value of the goods for duty and VAT;
  4. check whether a trade agreement lets you pay less or no customs duty;
  5. submit the declaration, yourself or through a transporter or customs agent;
  6. keep invoices and customs paperwork.

Decide at contract stage who is the importer of record: your UK distributor, your UK entity, or you. If an agent acts for you under direct representation, the importer remains liable for the declaration; under indirect representation the agent is jointly liable. Our guide to the CDS import declaration explains what the broker needs from you.

Any claim to preferential duty depends on the goods meeting the origin rules and on the right origin statement being in place, so ask your supplier and your broker to confirm origin before the first shipment rather than after it. For a practical overview from the exporter's side, see a guide for brands exporting cosmetics to the UK.

The seller's checklist at a glance

StageWhat to have ready
Before launchGB Responsible Person with a UK established address; safety assessment; English PIF
Before placing on the GB marketSCPN notification submitted by the RP
PackagingGB labels with RP name and address and all mandatory particulars
Leaving the EUExport declaration via AES; proof of exit kept
Arriving in GBGB EORI for the importer; commodity code; value; origin evidence; import declaration
Northern IrelandSeparate check: RP established in NI or the EU

If you are unsure whether to handle the declarations yourself, our page on whether you need a broker walks through the options.

Related guides

Shipping cosmetics from Poland to the UK?

Easy Clearance is a UK–EU customs clearance agency handling import and export declarations, T1/T2 transit and UK–Poland removals. Its guide covers the export side for cosmetics brands.

Read the Easy Clearance cosmetics guide

Sources

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.