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‘No Deal’ Brexit: UK Government Guidance to Business

29/08/2018

On 23 August, the UK Government issued a series of notices to provide guidance to businesses on how to prepare if the UK leaves the EU with no deal. These included:

  • Overview on preparations for a ‘no deal’ scenario
  • Applying for EU-funded programmes
  • Importing and exporting
  • Labelling products and making them safe
  • Regulating medicines and medical equipment
  • Studying in the UK or EU
  • Workplace rights

Among these, the notices specifically relevant for the cosmetics industry are those on importing and exporting, with two notices of particular interest:

 

On 13 September the UK Government released new technical notices to provide information on what a no-deal could mean to economic operators and the public. 

These papers are particularly important for non-UK businesses (or non-UK based responsible person) exporting goods to the UK market. The most relevant paper for the cosmetics industry is:

  • Appointing nominated persons to your business if there’s no Brexit deal: specifically mentions the Cosmetics Regulation and clarifies that
    For cosmetics, responsible persons based in an EU country will no longer be recognised by the UK after March 2019 (Regulation (EC) N° 1223/2009 is the main EU legislation covering cosmetics and covers the role of the responsible person). Businesses wishing to place cosmetics on the UK market will need to appoint a UK-based responsible person. This is due to specific legal duties assigned to the responsible person and their importance on ensuring the safety of products placed on the market.

Additional relevant papers are:

In the papers, the UK Government insists on the fact that a scenario in which the UK leaves the EU without agreement (a ‘no deal’ scenario) remains unlikely given the mutual interests of the UK and the EU in securing a negotiated outcome. However, it is important to keep in mind that even if a deal is agreed with the EU, it may not cover all technical challenges that will be faced by the cosmetics industry. 

CTPA is monitoring these issues with its EU Exit Strategy Group and is working closely with the Department for Business, Energy & Industrial Strategy (BEIS) on cosmetics specific issues.

CTPA is also providing confidential one-to one meetings with members to advise on contingency planning.