Sell cosmetics and skincare online in the UK: CPSR, notification, labelling and claims

This guide is for anyone about to sell skincare, make-up, haircare or fragrance online in the UK: own-label brands, small-batch makers and importers. We build Orbit Commerce, a hosted shop platform, so weigh the Orbit parts accordingly. Every rule and price was read at its source on 9 November 2026 and is linked; several changed in 2025 and 2026 and may change again.

What counts as a cosmetic, and who answers for it?

The UK Cosmetics Regulation (the retained Regulation 1223/2009) defines a cosmetic by use: anything put on the outer body, teeth or mouth mainly to clean, perfume or protect them, change their appearance, keep them in good condition or correct body odours (the text is quoted in MHRA Guidance Note 8). The gov.uk guide applies it to every cosmetic available to the public in Great Britain, free samples included. Hand-made soap, also a cosmetic, is in our soap and bath bomb guide; candles are not cosmetics and follow the CLP rules in our candle business guide.

Every product needs a responsible person. Under Article 4 a cosmetic “may not be placed on the market unless there is a responsible person established in the United Kingdom”, and gov.uk says a UK address “does not include mail forwarding or PO box addresses”. It can be the manufacturer, the importer, “a brand-owning distributor” or an appointee by written mandate; for an own-label brand that means you, unless your manufacturer has agreed in writing to take it on. Enforcement sits with “the Secretary of State or a local weights and measures authority” (regulation 2 of the 2013 Regulations): Trading Standards and OPSS.

What paperwork does a cosmetic need before its first UK sale?

1. A Cosmetic Product Safety Report (CPSR). Article 10 requires a safety assessment before the product goes on the market, by an assessor with “a diploma or other evidence of formal qualifications awarded on completion of a university course” in pharmacy, toxicology, medicine or a similar discipline. Part A is yours, Part B the assessor’s; you cannot sign it yourself without that qualification.

2. A Product Information File (PIF). Article 11: a description of the product, the CPSR, the manufacturing method and a good manufacturing practice statement, proof of any claimed effect and animal testing data, kept for ten years after the last batch, in English, at the address you notify.

3. A notification to OPSS. Before sale, Article 13 wants the product and responsible person details, the PIF address, an urgent contact, nanomaterials, CMR substances and the frame formulation; on sale you add the label and a packaging photo, and changes go in “without delay”. The Submit Cosmetic Product Notifications service needs a GOV.UK One Login and warns of “a fine and a prison term of up to 3 months if you do not notify OPSS”; neither it nor the gov.uk guidance mentions a fee.

4. A label that passes Article 19, uploaded with the notification.

What has to be on a cosmetics label in the UK?

Article 19 lists what the container and outer packaging must show:

• The responsible person’s name and address, plus the country of origin if imported. A label meeting the EU version of the rule is accepted until 31 December 2027 (OPSS statutory guidance, updated 29 June 2026).
• The nominal content, except under five grams or millilitres, samples and single-use packs.
• Durability: “best used before the end of” a date if the product keeps 30 months or less; otherwise the period-after-opening symbol and the period.
• Precautions from Annexes III to VI for your ingredients; the assessor lists them.
• A batch number and the function, unless obvious.
• The ingredients, headed “ingredients”, in descending order of weight, those under 1% in any order, “parfum” for perfume and “(nano)” after a nanomaterial, in the common glossary names, which is why it reads in INCI.

Fragrance allergens are where new brands slip. Annex III names 26 fragrance substances that must be written out above 0.001% in a leave-on product or 0.01% in a rinse-off one. The EU added 56 more: products placed on its market from 31 July 2026 need the longer list, earlier stock may sell until 31 July 2028 (European Commission), and Northern Ireland follows the EU. As at 9 November 2026 the Great Britain annex, revised to 15 August 2026, still stops at 26; anything sold into the EU or Northern Ireland needs the long list.

What can you say about a skincare product?

Article 20 says “text, names, trade marks, pictures and figurative or other signs shall not be used to imply that these products have characteristics or functions which they do not have”. Every claim must meet the six common criteria of Regulation 655/2013, which turn on truthfulness, “adequate and verifiable evidence”, honesty and fairness. The Advertising Standards Authority applies the CAP Code too, whose beauty advice (updated 2 February 2026) says objective claims “cannot be backed up with subjective consumer perception data”, and the MHRA decides when a claim makes a cosmetic a medicine. The table shows where common claims stood on 9 November 2026.

Guidance Note 8 says “Eczema, dermatitis and psoriasis are adverse medical conditions” and “Products to treat/prevent or fight spots and acne are medicines”. A cosmetic may say it is “Also suitable for people who may be prone to eczema / psoriasis / dermatitis / rosacea / acne / spots” where substantiated, as advice that never implies treatment. The MHRA’s borderline guidance (updated 2 July 2026) reads “customer reviews” as part of the presentation. On “clinically proven”, the ASA ruled on 29 April 2026 that a Eucerin poster’s claim rested on 160 volunteers’ self-assessment over four weeks, with no control group, and breached rules 3.1, 3.7 and 12.1 (ASA ruling). The technical document on cosmetic claims (EU working group, 2017, listed on the Commission’s cosmetics legislation page) is best practice rather than law.

Do reviews, influencer posts and photos count as advertising?

Yes. A review you publish is your claim: marketers must “hold documentary evidence that a testimonial or endorsement used in a marketing communication is genuine”, and claims within it “must not mislead” (CAP advice, Testimonials). Under Part 4 of the Digital Markets, Competition and Consumers Act 2024, “posting a fake review” or a review that conceals an incentive is banned, with the CMA and Trading Standards enforcing (Influencers’ guide to making clear that ads are ads, October 2026).

A review saying a cream “cleared my eczema” is a medicinal claim on your page; on Orbit the free Product Reviews plugin holds every review as Pending until you approve, reject or delete it (how reviews work). For influencers, “money, free products, or being an owner, employee, or friend of the brand” all count as payment, the fix is “a clear and prominent ‘Ad’ label upfront”, and “You, the brand and any agents” are responsible. Before-and-after photos need signed and dated proof that they are genuine (CAP advice, Before and after photos), and our product photography at home guide covers ordinary shots.

What changes when you sell into the EU or Northern Ireland?

In the EU only products with a responsible person “designated within the EU” may be placed on the market, so a British brand appoints one there to notify each product on the Cosmetic Products Notification Portal, “a free of charge online notification system” (European Commission, cosmetics legislation; CPNP). The EU label carries the 56 extra allergens from 31 July 2026. Northern Ireland sits under the EU regulation through the Windsor Framework. The responsible person must be “established in either Northern Ireland or the EU”, and notification goes through CPNP.

In Northern Ireland a product made in Great Britain counts as imported and “can say ‘made in UK’”, and GB sales still need the SCPN notification (OPSS Northern Ireland guidance, updated 29 June 2026). On Orbit you add the euro, store your IOSS number so it goes on every international label, and customs declarations use each product’s HS code; European cards cost 3% + 25p on Solo. Our guide to selling to the EU after the July 2026 parcel rules covers duty.

What does it cost, and what does skipping it cost?

Compliance is a fixed cost per formulation, so a tight range with shades as variants of one assessed base pays. Figures read on 9 November 2026; get three assessor quotes.

Skipping any of it costs more: under regulation 13 of the 2013 Regulations, breaching the safety, labelling or claims articles brings a fine, up to three months’ imprisonment or both, or up to £20,000, twelve months or both on indictment. Failing to keep the file or to notify brings a level 5 fine, three months, or both.

Setting up the shop, posting it, and the first ten orders

Keep the compliance facts with the product. On Orbit a cream or lipstick is a physical product with a weight, a shipping class and stock per location; shades and sizes are variants with their own price, SKU, barcode, image and stock, shown as swatches (products). Custom fields add the boxes cosmetics need, each with a storefront visibility switch: skin type as a pick-several list, the period after opening, the INCI list, and, kept internal, a file field for the CPSR (the custom fields guide). A gift set is a bundle of up to 30 physical products whose availability follows the scarcest component; ask us and we switch bundles on for your shop.

A refill every eight weeks is a subscription whose renewals charge the saved card and create an order with its delivery (subscriptions). Perfume, aftershave, nail varnish and aerosols are dangerous goods to carriers, and Royal Mail, Parcelforce and every courier publish a prohibited and restricted items list. Read your carrier’s before the first label and give those products their own shipping class whose delivery method exists only in the zones the carrier accepts. Checkout then refuses an item that cannot go to the typed address (shipping and fulfilment). The Google Shopping and Meta feed plugins build the product file on a schedule, each with a free tier, and every click checks out on your storefront (marketplaces and feeds; see our Facebook and Instagram shopping post).

Then the first ten orders:

1. Photograph every label as it goes out, so the picture in your PIF matches the label on SCPN.
2. Add a Batch custom field to orders and fill it as you pack, so a recall is a search in the Orders list, not a guess.
3. Decide now what you will do if someone reports a reaction: a serious undesirable effect goes to OPSS immediately.

Where Orbit fits

Everything above about the shop is on every Orbit plan, Solo included at £25 a month or £19 a month billed yearly, ex VAT. That covers unlimited products with variants and custom fields, bundles once we switch them on, subscriptions, gift cards, shipping classes, the free Product Reviews plugin, extra currencies, and hosting on AWS in London with SSL. There is one published card rate per plan, 2% + 25p for UK personal Visa and Mastercard on Solo, with nothing on top. The 14-day trial needs no card. In the theme store, Petal is a soft, clean skincare theme with an ingredient panel, and Boutique Soft a warm, softly rounded theme for skincare, beauty and wellness brands. Pick either and change its colours, fonts and logo in the dashboard.

Read next: selling supplements online and what you may claim, selling to Ireland and the EU in euros and the new UK rules for selling subscriptions.

Questions people ask about selling cosmetics and skincare online in the UK

Do I need a CPSR to sell skincare online in the UK?

Yes. Article 10 of the UK Cosmetics Regulation requires a safety assessment and a Cosmetic Product Safety Report before any cosmetic is placed on the market, signed by an assessor qualified in pharmacy, toxicology, medicine or a similar discipline. It applies to every product sold or given away in Great Britain, with no exemption for small or handmade ranges.

Can I call my product natural, organic or hypoallergenic?

Only with evidence behind each word. CAP says a product is not “natural” merely because it leaves out a common ingredient. The UK has no standard for organic cosmetics, so name the certification you meet; about 5% organic ingredients was ruled misleading. “Hypoallergenic” fits only a product designed to minimise its allergenic potential, with evidence, and must not promise an absence of risk.

Can I say my cream treats eczema or acne?

No. The MHRA treats eczema, dermatitis, psoriasis and acne as adverse medical conditions, so a product that claims to treat, prevent or fight them is a medicine needing a marketing authorisation. You may say “Also suitable for people who may be prone to eczema / psoriasis / dermatitis / rosacea / acne / spots” where substantiated, as advisory wording only.

Do I need a new safety report for every shade or scent?

Each formulation needs its own assessment, but assessors treat a shade or scent change on the same base as a variant of one report and price it that way: one UK provider adds £30 for two variants, rising to £60 for five. A change to the base is a new product; your assessor decides what counts as a variant.

Do I need a separate responsible person to sell into the EU or Northern Ireland?

Yes. The EU needs a responsible person established in the EU, who notifies the product on the Cosmetic Products Notification Portal, free of charge. Northern Ireland follows the EU regulation under the Windsor Framework, so the responsible person must be in Northern Ireland or the EU and the product goes on CPNP; sold in Great Britain too, it also needs the SCPN notification.

While the assessor works, the shop can be ready first: the 14-day free trial, no card required, is time enough to build the catalogue before the first jar is notified.