One CPSR for the UK and EU? Dual Market Safety Reports After Regulatory Divergence

Picture a small brand that launched a gel nail range in Manchester in 2024 with a perfectly good CPSR. A year later a distributor in Rotterdam asks for the safety report so they can list the range in the Netherlands. The report was sound, but it had been written against the UK Cosmetics Regulation only, and one of the base gels contained TPO. In the EU, TPO had been banned outright from 1 September 2025. In Great Britain it was still legal and stayed legal until August 2026. Same product, same report, legal in one market and not in the other.

That is the dual market problem in one example, and it is a very common one. The two regulations started as the same text, and on paper they still look almost identical. Underneath, the ingredient lists have been drifting apart since January 2021. So the short answer to the question we get every week is yes, one CPSR can cover the UK and the EU, but only if it was written to cover both. This guide explains what that means in practice.

Why one report can work at all

At the end of 2020 Great Britain kept Regulation (EC) No 1223/2009 as domestic law. The GB version sits on legislation.gov.uk, was adapted by SI 2019/696 and is enforced through the Cosmetic Products Enforcement Regulations 2013. The core of both texts is unchanged: the same definition of a cosmetic, the same general safety duty in Article 3, the same Annex I format for the safety report, the same Product Information File and the same Responsible Person model.

That matters because the structure of a CPSR does not change between markets. Part A still covers the formula, physical and chemical characteristics, microbiology, impurities, packaging, use, exposure and the toxicological profile of each ingredient. Part B still holds the assessor's conclusion, label warnings and reasoning. Most assessors on both sides still work from the SCCS Notes of Guidance for exposure figures and margin of safety, so the toxicology section of a well written report rarely needs changing for the second market. The work that differs is the regulatory screening and the labelling. If you want a refresher on the parts of the report, our guide to what a CPSR is walks through them.

Where the two rulebooks now differ

The annexes are where the split shows. The EU amends them several times a year through omnibus regulations based on opinions of the Scientific Committee on Consumer Safety. Great Britain amends them through its own statutory instruments, on advice from its Scientific Advisory Group on Chemical Safety, usually later and sometimes with a different result. Here are the changes most likely to touch a small brand in 2026.

Change	European Union	Great Britain
TPO (trimethylbenzoyl diphenylphosphine oxide), the photoinitiator in many gel nail products	Banned from 1 September 2025 by Regulation (EU) 2025/877, with no sell-through period	Banned by SI 2026/23 for products placed on the market from 15 August 2026; older stock may be sold until 14 February 2027
4-MBC (enzacamene), a UV filter	Banned by Regulation (EU) 2024/996: no new products from 1 May 2025, off shelves by 1 May 2026	Banned by SI 2026/23 from 15 July 2026; existing stock may be sold until 14 January 2027
The 'releases formaldehyde' warning	Required once released formaldehyde reaches 0.001% in the finished product (Regulation (EU) 2022/1181, applying since 31 July 2024)	The same 0.001% threshold, but only from 15 July 2026 under SI 2026/23; products labelled to the old rule may be sold until 14 January 2027
Benzophenone-3 (oxybenzone) limits	Tightened in 2022 by Regulation (EU) 2022/1176	Tightened separately by SI 2025/901 from 21 January 2026, with sell-through to 21 July 2026
Fragrance allergen labelling	Expanded list in Regulation (EU) 2023/1545: new products placed from 31 July 2026 must comply, existing products by 31 July 2028	Still the original list of 26 allergens at the time of writing
CMR substances added in 2026	Regulation (EU) 2026/78 (Omnibus VIII) applies from 1 May 2026	GB adds newly classified CMRs through its own instruments, on its own dates, so the two Annex II lists do not match line for line

Notice the pattern. Most of the time Great Britain reaches a similar conclusion to the EU, a year or two later, with a sell-through period the EU did not give. Sometimes it does not follow at all: the EU cut homosalate to 7.34% in face products only, while GB kept its 10% limit. Those gaps are exactly what trip people up. A product can be legal to place on the GB market in a given month and illegal in the EU in the same month. For the GB side in detail, see our summary of UK cosmetic regulation changes in 2026, and for the EU side our guide to Omnibus VIII.

What a dual market CPSR must actually contain

When we write a report for both markets, these are the things an enforcement officer in either market should be able to find without hunting.

• Both legal bases, named. The report states that the product was assessed against the GB Cosmetics Regulation and against Regulation (EC) No 1223/2009 as currently amended in the EU.
• An ingredient screen against both sets of annexes. Every INCI is checked against Annexes II to VI in each market, and any ingredient treated differently is flagged, with the stricter position applied.
• Two allergen calculations where needed. With the expanded EU list now in force for new products, the report sets out which allergens must be declared on an EU label and which on a GB label, using the 0.001% leave-on and 0.01% rinse-off thresholds.
• Warnings for each market. If one market requires a warning the other does not yet require, such as the formaldehyde warning during the GB transition, the report says which label needs it.
• A clear conclusion for each market. Safe for the GB market, safe for the EU market, with any condition that applies to only one of them.
• The assessment date and the annex versions checked. Divergence is ongoing, so anyone reading the report later needs to know what it was measured against.

The assessor's qualification rules in Article 10 are the same in both texts, so one qualified assessor can sign a report for both markets. What matters is that the person signing actually works with both sets of annexes. Phoenix writes single and multiple variant CPSRs as dual market reports on request, from our London and Estonia offices.

Formulate once, to the stricter rule

The cheapest way to sell one product in both markets is one formula that is legal in both. In practice that means taking the stricter position for every ingredient. If the EU has banned something GB still allows, leave it out. If a preservative limit is lower in one market, use the lower limit. If GB ever restricts something the EU still allows, respect that too.

Two formulas, one tuned to each market, sounds flexible but doubles the safety assessment, the PIF, the batch records and the stock management, usually for a tiny gain. Almost every small brand we advise is better off with one formula and, where necessary, two labels.

The time to check is before the formula is frozen, not after the report is written. A quick screen of a draft INCI list against both sets of annexes costs very little. Finding out after launch that your hero ingredient is banned in your second market costs a reformulation, new stability data and a new report.

What still has to be done twice

Even with one report, three obligations are tied to the market itself.

The Responsible Person

The Responsible Person must be established in the market where the product is placed. A UK company can act for Great Britain but not for the EU, and an EU company can act for the EU but not for Great Britain. So a brand selling in both has two Responsible Persons, each holding the PIF for its market and each named on the label. Our comparison of the UK and EU Responsible Person roles goes into who can do what, and Phoenix provides both through its UK Responsible Person and EU Responsible Person services.

The notification

Products for Great Britain are notified on SCPN, the UK's Submit Cosmetic Product Notifications service. Products for the EU are notified on the EU's CPNP. The two systems are run separately, need separate accounts held by the relevant Responsible Person, and share nothing. A notification in one never counts in the other. Our explainers on SCPN and CPNP cover each process.

The label

Each label has to show the name and address of the Responsible Person for that market, the allergens that market requires, and the language of the country of sale for EU member states. Imported products also need the country of origin, and a product made in the EU is an import into Great Britain, and the other way round. Many brands print one label carrying both Responsible Person addresses and the longer EU allergen list, which works in both markets because naming extra allergens on a GB label is not a problem. Others print two runs. Either approach is fine if each label meets its own market's rules. A label and packaging review against both sets of rules before you print is cheap insurance.

Northern Ireland: the market people forget

Under the Windsor Framework, cosmetics placed on the market in Northern Ireland follow EU cosmetics law, not the GB version. That means EU annexes, EU allergen labelling on the EU timetable, CPNP notification, and a Responsible Person established in Northern Ireland or the EU. A brand that sells across the whole of the UK is already a dual market brand, whether it has thought about it or not. A dual market CPSR covers Northern Ireland without extra work, as long as the EU side has been done properly. We cover the detail in our guide to selling cosmetics in Northern Ireland.

A worked example: a lavender body lotion sold in London and Berlin

A small British brand sells a lavender body lotion in Great Britain and, through a German distributor, across the EU. The assessor screens the formula against both sets of annexes. The preservative system is allowed at the level used in both markets, and nothing in the formula is on either Annex II.

The difference turns up in the fragrance. The lavender oil brings linalool, limonene, geraniol and coumarin, which are on the original list of 26 and must be declared in both markets above 0.001% in a leave-on product. Under Regulation (EU) 2023/1545, the EU label also has to declare linalyl acetate and terpineol, and the lavender oil itself, above the same threshold. Because this lotion is first placed on the EU market after 31 July 2026, the expanded list applies to it straight away.

The assessor concludes the lotion is safe for both markets and sets out two allergen declarations: the shorter one GB requires and the longer EU one. The brand decides to print one label with the longer list and both Responsible Person addresses, which satisfies both markets. It acts as its own Responsible Person in Great Britain, appoints an EU Responsible Person in Estonia, notifies on SCPN and CPNP, and keeps a PIF in each market. When the EU later amends an annex that affects one of the fragrance constituents, the assessor issues an addendum for the EU side only, and both PIFs record the change.

Already have a GB only or EU only report?

It is rarely wasted. Ask the original assessor, or a new one, to extend it. That means screening every ingredient against the other market's current annexes, adding the second allergen calculation, checking warnings, and issuing an addendum that states the conclusion for the second market and the date. If the screen finds a problem ingredient, the addendum says so and you either reformulate for both markets or keep a separate formula for one.

An extension usually costs a fraction of a new report, as long as the original is sound and recent. A report several years old, or one built on supplier documents that have since been updated, is often better replaced. If your products are made outside the UK and EU, our guide to CPSRs for imported cosmetics covers the extra documents to collect.

Keeping the report current in both markets

Because the two regulations move on their own timetables, a dual market report needs a watch on both. Review it at least once a year, and whenever either market amends an annex that touches one of your ingredients. When that happens, the assessor issues an addendum for the affected market, both PIFs are updated, and the label is changed if it needs to be. Keep a short change log in each PIF saying which market's rule changed and what was done. A report that was right for both markets last year is not automatically right for both this year.

The mistakes we see most often

• A GB only report used for EU sales, or the reverse, with no screen against the other market's annexes.
• One Responsible Person for both markets. It is not possible; each market needs its own.
• Notifying on SCPN and assuming CPNP is covered. The systems do not talk to each other.
• Forgetting Northern Ireland, which runs on EU rules.
• Using one market's allergen list on the other market's label, especially now the EU list has expanded for new products.
• Tracking only the EU. GB sets its own dates and sell-through periods, and does not always land on the same limit.

Related reading

• What is a CPSR? The UK and EU guide
• UK cosmetic regulation changes in 2026
• EU Omnibus VIII: what it bans
• Fragrance allergen labelling: the expanded EU list
• Selling cosmetics in Northern Ireland
• UK vs EU Responsible Person
• What is SCPN?
• What is CPNP?
• CPSR for imported cosmetics
• The margin of safety in cosmetic toxicology
• All regulatory compliance articles

Myths we hear

• My UK CPSR covers the EU because the regulations are the same. The text started the same, but the annexes have diverged. A report that never screened against the EU annexes does not cover the EU.
• One Responsible Person can cover both markets. Each market needs a Responsible Person established there. A UK company cannot be your EU Responsible Person, and an EU company cannot be your GB one.
• Notifying on SCPN also notifies the EU. SCPN and CPNP are separate systems with separate accounts. A notification in one never counts in the other.
• Northern Ireland follows GB rules. Under the Windsor Framework, Northern Ireland applies EU cosmetics law, including CPNP notification and the EU allergen list.
• GB always copies the EU, so I only need to track Brussels. GB often reaches a similar result later, with its own dates and sell-through periods, and sometimes it keeps a different limit altogether. You need to watch both.

What to do this week

1. List every product you sell or plan to sell in Great Britain, the EU and Northern Ireland, and note which markets each one is actually in.
2. Check whether each CPSR names both regulations and gives a conclusion for each market. If it names only one, ask for an extension or addendum.
3. Screen every formula for TPO, 4-MBC, benzophenone-3 levels and formaldehyde-releasing preservatives, and note the GB and EU dates that apply to each.
4. Run the expanded EU allergen calculation for any fragranced product you are placing on the EU market as new, and plan label changes for existing products before 31 July 2028.
5. Confirm you have a Responsible Person in each market and that both addresses appear on the right labels.
6. Check that every product sold in the EU and Northern Ireland is notified on CPNP and every product sold in GB is on SCPN.
7. Put an annual review date in the diary for each dual market report, plus a check whenever either market amends an annex.

Frequently asked questions

Official sources and legislation

• Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
• GB Cosmetics Regulation (assimilated Regulation 1223/2009, legislation.gov.uk)
• Cosmetic Products Enforcement Regulations 2013 (SI 2013/1478)
• SI 2026/23: GB ban on 4-MBC and new CMRs including TPO, and the formaldehyde warning threshold
• SI 2025/901: GB conditions for benzophenone-3
• Regulation (EU) 2025/877 (Omnibus VII, CMR substances including TPO)
• Regulation (EU) 2024/996 (4-MBC and other ingredients)
• Regulation (EU) 2022/1181 (formaldehyde releaser warning)
• Regulation (EU) 2023/1545 (expanded fragrance allergen labelling)
• Regulation (EU) 2026/78 (Omnibus VIII)
• OPSS: making cosmetic products available to consumers in Great Britain
• Submit Cosmetic Product Notifications (SCPN)