In short: to sell fragrance in Great Britain you need a Responsible Person established in the UK, and that Responsible Person must notify each product through the SCPN service before it is placed on the market. A European CPNP notification does not carry over. Great Britain and Northern Ireland now run on two different notification systems, and the label has to match the system you are selling into.
What actually changed at the end of the transition period
Great Britain — England, Scotland and Wales — is governed by Regulation (EC) No 1223/2009 on cosmetic products as amended by the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019. Northern Ireland follows a separate regime, and OPSS publishes its own guidance for that market (Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013: Great Britain).
The main changes took effect at 11pm on 31 December 2020. Four of them decide whether your shipment can be sold:
- Responsible Person. There must be a Responsible Person based in the UK.
- Product Information File. An up-to-date PIF must be kept in English and made available to market surveillance and enforcement authorities at the UK address you provided.
- Notification. The UK government established the Submit Cosmetic Product Notification (SCPN) service to replace the EU’s Cosmetics Products Notification Portal (CPNP) in Great Britain. Products not previously notified through CPNP, not placed on the EEA market, or placed on the GB market after 31 December 2020 must be notified through SCPN before they can be placed on the market.
- Labelling. A transition period applies before the UK Responsible Person’s details have to appear on the pack — the detail worth checking carefully, and covered below.
Where the three markets now sit:
| Great Britain | Northern Ireland | EU | |
|---|---|---|---|
| Notification service | SCPN | CPNP | CPNP |
| Responsible Person based in | UK | NI or the EEA | EU / EEA |
| Legal basis | GB version of Regulation (EC) No 1223/2009 | Regulation (EC) No 1223/2009 as it applies in NI | Regulation (EC) No 1223/2009 |
OPSS is explicit that businesses placing cosmetics on the GB market must notify through SCPN via their UK Responsible Person, while businesses placing cosmetics on the NI market notify CPNP via a Responsible Person based in NI or the EEA (New data on UK cosmetic product safety notifications).
Who can be the UK Responsible Person
This is the first question a UK launch usually dies on, because the answer cannot be your factory.
Someone has to be the cosmetic product’s Responsible Person, and under the GB regime that party must be established in the UK. The role can be filled by (OPSS — submit a cosmetic product notification):
- the manufacturer
- the importer
- the distributor, if they label the product as their own — for example under their own brand name
- an appointed company or person, authorised by the manufacturer or the importer
Two consequences follow for a fragrance brand sourcing from China. First, the brand — not the factory — is usually the natural candidate, because the brand is the party whose name goes on the pack. Second, since 1 January 2021 a UK business bringing cosmetic products into GB from an EU member state is an importer rather than a distributor, and the importer of a cosmetic product becomes the Responsible Person by default, though they may appoint an agent to hold the role instead.
A manufacturer in Guangzhou cannot sign up as the UK Responsible Person. What it can do is supply the technical file that makes the notification possible.
What you have to submit to SCPN
OPSS lists the information you need in hand before you start a notification. In practice this list is also the checklist a brand should assemble long before it talks to a UK retailer:
- the category and name of the cosmetic product
- the name of the Responsible Person
- where the Product Information File is kept
- details of a named contact for urgent enquiries
- details of any nanomaterials the product contains
- details of any carcinogenic, mutagenic or toxic for reproduction (CMR) substances it contains
- the chemical details of the substances
- a summary of the ingredients
- an image of the product’s label
- a photograph of the product packaging
Two entries on that list are where fragrance projects stall. The summary of ingredients and the chemical details of the substances have to come from whoever formulates the scent — which is the fragrance house, not the brand and not the label printer. And the image of the label and photograph of the packaging must show the finished artwork, so a notification cannot honestly be submitted while the layout is still moving.
The labelling transition, and why two official pages disagree
There is a genuine discrepancy in the public guidance, and it is better to know about it than to discover it at the port.
The current OPSS guide to the GB regime states a seven-year transition period from 1 January 2021 before businesses have to include the UK Responsible Person’s details on product labels, provided the EU responsible person’s details are included. That reads as the end of 2027.
The SCPN guidance page, which was last updated in December 2020, states that all product packaging must bear the name and address of the UK Responsible Person from 31 December 2022 for products previously on the EU market before 1 January 2021.
These are not the same date. The later guidance is the one that reflects the transition period OPSS describes, but the pack in your warehouse is the thing that gets inspected. Confirm the applicable date with your UK Responsible Person against the current guidance, and be aware the older wording is still widely repeated in agency blogs and on consultancy sites.
Fragrance-specific points that catch brands out
The allergen list is not automatically the EU list. The UK version of Regulation (EC) No 1223/2009 on legislation.gov.uk is kept up to date with amendments made by UK legislation; it is not a live mirror of the EU text, and the EU Exit Web Archive holds the snapshot as at IP completion day, 31 December 2020 (Regulation (EC) No 1223/2009 — UK version). If your labelling artwork was built from a post-2020 EU allergen update, check it against the GB text rather than assuming the two moved together.
Novel nanomaterials need six months’ notice. A cosmetic product containing a novel nanomaterial not used as a colourant, preservative or UV filter must be notified to the Secretary of State through SCPN by the Responsible Person six months before it is placed on the GB market.
Aerosol packs have their own rules. For cosmetic products supplied in aerosol dispensers, the dispenser must meet the Aerosol Dispensers Regulations 2009, which includes the UKCA marking requirement. UKCA became compulsory from 1 January 2022, and until 31 December 2027 the marking may be affixed to a label or a document accompanying the dispenser. A room spray or spray fragrance in an aerosol can needs this checked separately from the cosmetic notification itself.
Serious undesirable effects go to OPSS. Reporting runs through the UK SUE form to OPSS, not the EU route. A brand with a complaint-handling process built for CPNP needs a second path for the UK.
What the SCPN data tells you about enforcement
SCPN is not a filing cabinet. As of 28 May 2026 there had been 861,686 notifications to the system since its launch in December 2020, submitted by 24,112 registered Responsible Persons. OPSS has also taken action where products notified through SCPN were found to contain banned chemicals, requiring businesses either to correct the information or to remove the products involved (New data on UK cosmetic product safety notifications).
Read those two facts together and the practical message is straightforward: the notification record is the enforcement authority’s starting point. Anything inconsistent between your SCPN entry, your PIF, your label and the product in the carton is discoverable.
A pre-launch checklist for a UK fragrance range
Run this in order. Each step depends on the one above it.
- Name the UK Responsible Person in writing. Confirm they are established in the UK and that they accept the role for each SKU.
- Build the PIF in English and keep it at the UK address you gave the authorities.
- Collect the formulation data for every SKU from the fragrance house — ingredient summary and chemical details of the substances.
- Settle the artwork for label and packaging, then photograph both.
- Confirm the labelling date that applies to your pack, given the discrepancy between the two official pages.
- Check the allergen declaration against the GB text of the Regulation, not a post-2020 EU update.
- Notify through SCPN before any product is placed on the GB market.
- Screen for aerosols, and handle the Aerosol Dispensers Regulations 2009 and UKCA marking separately if they apply.
- Set up SUE reporting to OPSS alongside your existing process.
- Decide the NI question. Great Britain and Northern Ireland are separate; if you are selling into both, you are maintaining two notification records.
The pattern behind that list is worth naming: none of it is about the scent. A fragrance can be excellent and still fail to reach a UK shelf because the notification record, the PIF and the label did not agree with each other.
FAQ
Do I need a UK Responsible Person if my product is already notified on CPNP?
Yes. CPNP notification covers the EU and Northern Ireland. Great Britain requires its own notification through SCPN, and only a Responsible Person established in the UK can submit it.
Can my Chinese manufacturer be the UK Responsible Person?
No. The Responsible Person must be established in the UK. The role can sit with the manufacturer or importer established in the UK, a distributor who labels the product as their own, or an appointed company authorised by the manufacturer or importer.
What is the deadline for notifying a new product on SCPN?
Notification must be completed before the product is placed on the GB market. Products that had already been notified on CPNP before 1 January 2021 had until 31 March 2021 to notify through SCPN.
Does the EU allergen list apply in Great Britain?
Not automatically. The GB version of Regulation (EC) No 1223/2009 is updated with UK amendments rather than tracking the EU text, so allergen declarations should be checked against the GB version.
Is SCPN the same as the Cosmetic Products Enforcement Regulations 2013?
No. SCPN is the notification service. The Cosmetic Products Enforcement Regulations 2013 are the GB enforcement regulations, and OPSS publishes a guide covering how the Regulation and those enforcement regulations work together.
What happens if a notified product contains a banned substance?
OPSS has taken enforcement action in exactly that situation, requiring businesses to correct their information or remove the products concerned. The notification record is where that review starts.
Do I need to notify separately for Northern Ireland?
Yes. NI uses CPNP, with a Responsible Person based in NI or the EEA. Products placed on the NI market must notify CPNP, and Northern Ireland Responsible Persons must also notify the GB regulator through SCPN with the ingredients and flag unsafe products.
Launching a UK fragrance range
Senti manufactures perfume and home fragrance in Guangzhou, and UK compliance is one of the stages we are asked about most often by brands preparing a launch. We are not the UK Responsible Person and we cannot be — but the formulation data, ingredient summary and chemical details that a notification depends on come out of our development work, and brands that involve us early spend far less time re-doing artwork later.
If you are planning a UK range, the useful starting point is our guide to launching a perfume brand with an OEM manufacturer, followed by how our OEM, ODM and OBM services differ. Our custom perfume service covers formulation and filling, scented candles and reed diffusers cover the home fragrance side, and private label perfume solutions sets out what a full launch programme looks like. On the logistics side, shipping perfume internationally explains the Incoterms and hazmat questions that sit next to the compliance ones.
Tell us your target market and the SKUs you are launching, and we will put together the formulation and ingredient data your UK Responsible Person needs to submit the notification. Talk to our team.
