In 2016, the UK voted to leave the European Union. On January 31, 2020, Britain left the European Union. As of January 1, 2021, the transition period ended, and like all other industries, the beauty industry now must adhere to new regulations and trade formalities. Tariffs and taxes, red tape, and customs delays have compounded COVID-related problems for retailers and brands. The general consensus around Brexit is confusion and uncertainty among brand owners when it comes to the subject—everyone is actively figuring it out. From having two portals to register on, to duplicate labeling and customs forms, being compliant in the UK and the EU now requires double the work and cost.

Karim Jiwani, MILT, Logistics Manager at Cult Beauty, said the past two months have been challenging because in his belief the UK didn’t do a proper drill-down with supply-chain companies to clarify the processes and requirements that could have helped facilitate the Brexit transition. Jiwani and the Cult Beauty team have not only had to educate themselves and navigate the changes for their own business but had to simultaneously educate their current brands, especially those not based in the EU. Throughout the process he said they remained focused on Logistics 101: “What do we need to put in place to ensure we get our products from A to B without disrupting the supply chain?” Jiwani reinforced the importance of being precise with the documentation you file, whatever customs formalities have been imposed, otherwise customs will not allow the shipment to transit through to the UK.

Some Brexit Basics

Registration needs:

• The UK Cosmetics Regulation (UKCR) is in principle a replica of the EU Cosmetics Regulation.
• Cosmetic products intended for sale in the UK and EU now need to be notified on two separate notification portals: the EU Cosmetic Product Notification Portal and the UK’s new SCPN.

Responsible Person (RP):

• You must have a Responsible Person in both the UK and EU to continue to sell products within both markets.
• It is not necessary to have an internal RP; there are many companies that offer this service.
• Product labeling must reflect the corresponding RP address.

Documentation needs for import and export between UK and EU:

• Commercial Invoice
• Certificate of Origin
• The Costing Bill of Materials
• Origin Declaration

Jiwani predicts it will take some time for things to settle down, but he’s seeing green shoots as companies begin to acclimate to the new norm of handling freight. However, it’s also important for all supply chains to have the correct processes and competence in order to have a frictionless operation. It’s a learning curve for everyone, but communication internally and with external partners is crucial. Jiwani recommends skipping emails and opting for actual live conversations to mediate holdups or to get clarifications along the way.

For a more detailed discussion on Brexit, view our BeautyMatter Brexit Workshop on demand with Karim Jiwani, along with Carys Smith, Regulatory and Sales Director for Ayton Global Research, and Dr. Modjan Moddaresi of Personal Care Regulatory Ltd., PhD, PharmD, FRSB, CBiol, MRSB.