Does a UK CPSR work in the EU?
Partly. The data behind a GB safety report usually travels; the designation does not. An EU launch needs a responsible person designated within the Union (Art. 4(1), Reg. (EC) 1223/2009), a CPNP notification made by that person (Art. 13(1)), and a report that holds against the EU Annexes as they stand. A GB responsible person and an SCPN notification cover Great Britain only.
What carries over from a GB file, and what is redone
| What you have | Into an EU file? |
|---|---|
| Stability, challenge tests, certificates of analysis | Yes — usually the expensive half you already bought |
| A UK safety report | Read, not assumed. Send it; we say what is usable before anything is redone |
| A GB responsible person | No — Art. 4(1) requires designation in the Union |
| An SCPN notification | No. CPNP is a separate submission by the EU responsible person (Art. 13(1)) |
| Your artwork | Needs the EU responsible person's name and address (Art. 19(1)(a)) |
The data travels. The signature and the designation do not.
Who may sign. Art. 10(2) is a qualification requirement, not an establishment requirement: a safety assessor is not ruled out by being in the UK. What decides whether a report can be used is what is in it.
The Annexes have moved apart. The report has to hold against the EU Annexes in force. Great Britain and the EU have amended their annexes separately since 1 January 2021, so a GB report can be sound in GB and out of date for the EU — the EU's fragrance-allergen amendment, Regulation (EU) 2023/1545, is one example. What that amendment changed →
Can a UK-established company be the EU responsible person?
No. Art. 4(1) requires a responsible person designated within the Union. The UK government's own guidance for Northern Ireland says the same thing from the other side: "Responsible Persons cannot be based in Great Britain" (OPSS, Northern Ireland guidance).
That is not a comment on UK providers. The establishment requirement is separate. How Art. 4 places the role →
SCPN or CPNP: which portal, which responsible person
| Market | Responsible person established in | Notification |
|---|---|---|
| Great Britain | the UK | SCPN, the UK's Submit cosmetic product notifications service |
| EU / EEA | the Union | CPNP (Art. 13(1)) |
| Northern Ireland | Northern Ireland or the EEA — not Great Britain | CPNP |
For Great Britain, OPSS states that "a Responsible Person must have a UK established address to make cosmetic products available in GB" (OPSS, GB guidance). So one product sold in both Great Britain and the EU needs both notifications, made by two responsible persons — one established in the UK, one in the Union — unless one entity is established in both.
Northern Ireland
Under the Windsor Framework, Northern Ireland applies Regulation (EC) 1223/2009. The responsible person must be established in Northern Ireland or the EEA, and the product is notified on CPNP. A GB brand selling into Northern Ireland therefore faces the EU requirements, not the GB ones (OPSS, Northern Ireland guidance, updated 29 June 2026).
Questions people ask
Do I need both a UK and an EU responsible person?
If you sell in both Great Britain and the EU, yes: one established in each — unless one entity is established in both.
Does my UK responsible person cover Northern Ireland?
Not if they are based in Great Britain. For Northern Ireland the responsible person must be established in Northern Ireland or the EEA.
Can a UK safety assessor sign my EU CPSR?
Art. 10(2) sets a qualification, not a location. Whether the report can be used depends on what is in it — send it and we will say.
Does a UK CPSR or a UK Responsible Person cover the EU?
The designation does not. What of the report can be reused is a question about your document.
Tell us the product, the variants and the markets — a fixed quote in writing.