Selling Cosmetics in Northern Ireland: Windsor Framework Rules and CPNP Notification Requirements for UK Brands

The order came in from Belfast on a Tuesday, the same as any other order. The Manchester soap brand packed it, posted it, and thought no more about it until Etsy asked, a week later, for the name and address of its EU Responsible Person. That is the moment most Great Britain brands discover the Windsor Framework. Under the Framework, the arrangement that replaced the Northern Ireland Protocol, Northern Ireland continues to apply the EU regulation on cosmetic products, Regulation (EC) No 1223/2009 as it stands in the EU today, rather than the UK Cosmetics Regulation that governs England, Scotland and Wales through the Cosmetic Products Enforcement Regulations 2013. The two have diverged since 2021, and the practical consequences for a cosmetic brand are the same as selling into Ireland or Germany: an EU Responsible Person, CPNP, EU labelling and the EU annexes.

This guide sets out what the Framework means for cosmetics, who the Responsible Person must be, how notification works, what the label must carry, how annex and allergen divergence bites, the position of goods moving between Northern Ireland and Great Britain, what marketplaces do, how enforcement works, a worked example of the Manchester brand's choices, and a practical route for any GB brand that wants to sell across the whole United Kingdom compliantly. The Belfast order is not a problem. Not knowing the rules is.

What the Windsor Framework means for cosmetics

The Framework keeps Northern Ireland aligned with the EU single market for goods to avoid a hard border on the island of Ireland. For cosmetics that means the EU regulation applies in Northern Ireland in its current EU form, including every amendment to the annexes and the allergen labelling rules adopted by the EU since 2021, and including the requirement for a Responsible Person established in the EU or Northern Ireland and notification through the EU's portal. The UK Cosmetics Regulation applies in Great Britain only. A brand selling in Belfast and in Birmingham is selling under two legal regimes, and the regime in Belfast is the EU one.

The Responsible Person

The EU regulation requires a Responsible Person established within the market where the product is placed, and for Northern Ireland the EU treats establishment in Northern Ireland as establishment in the relevant territory. A company registered in England is established in the UK but not in the EU or Northern Ireland, so it cannot be the Responsible Person for its own Northern Ireland sales. The options are a Northern Ireland establishment, an EU subsidiary, or an appointed Responsible Person service established in the EU or Northern Ireland. Phoenix's Estonian office provides EU Responsible Person services that cover Northern Ireland as part of the EU market, holding the PIF and appearing on the label.

Notification through CPNP

Products placed on the Northern Ireland market are notified through CPNP by the EU or Northern Ireland Responsible Person, not through SCPN. A GB brand already notified through SCPN has not notified for Northern Ireland. The CPNP notification uses the same frame formulation, product category and label information, with the EU Responsible Person's details and an EU compliant label image. Our notification service handles CPNP alongside SCPN from one submission, and our guide to frame formulations explains the composition declaration.

The label

A product sold in Northern Ireland must carry an EU or Northern Ireland Responsible Person's name and address, must comply with the EU allergen labelling rules on the EU timetable, and must meet the EU annex conditions for any required warnings. English is the language of Northern Ireland, so no translation is needed. Most GB brands resolve this with a single UK wide label carrying both the GB Responsible Person and the EU or NI Responsible Person, and the EU expanded allergen list, which satisfies both regimes; the alternative is a separate Northern Ireland label. Either way the artwork goes in both PIFs. Our label review checks a UK wide label against both regimes.

Annex divergence and the CPSR

Because the EU annexes apply in Northern Ireland, a formula must satisfy the EU restrictions and prohibitions as amended, which now differ from the UK annexes in a number of entries. A CPSR that assesses only against the UK Cosmetics Regulation does not cover Northern Ireland; the report must assess against the EU regulation as well, and the practical approach is a dual market report that formulates to the stricter position for each ingredient. Our guide to dual market CPSRs covers this in full, and every Phoenix CPSR can be prepared as dual market on request, or extended by addendum if you already hold a GB report.

Marketplaces and Northern Ireland

Amazon, Etsy and other platforms increasingly apply EU compliance checks to orders and listings involving Northern Ireland, because the platforms' systems treat it as within the EU goods regime. A GB seller may receive a request for an EU Responsible Person or EU compliance documents for a product it regards as sold domestically. This is not an error; it reflects the Framework. Sellers who have not set up Northern Ireland compliance can restrict delivery to Great Britain in their platform settings, and many do; sellers who wish to serve Northern Ireland customers should have the EU documents ready before the request arrives.

Timing your move: allergen dates and print runs

The EU's expanded allergen list creates a practical timing question for any brand adding Northern Ireland. Products placed on the Northern Ireland market from 31 July 2026 must carry the expanded declarations, and products already there must comply by 31 July 2028. A GB brand moving into Northern Ireland after the first date has no transition at all: its first Northern Ireland units must already carry the longer list. Because a UK wide label satisfies both regimes by carrying the longer list, the sensible sequence is to have the assessor produce the expanded allergen declaration as part of the dual market addendum, plan the label change for the next print run, and start Northern Ireland sales only once that label is on the shelf. Brands that print a GB only label in the meantime are printing stock they cannot send to Belfast.

What Northern Ireland based brands should know

The Framework cuts the other way for a brand established in Northern Ireland, and mostly to its advantage. Such a brand can be its own Responsible Person for the EU regime, because establishment in Northern Ireland counts, so it can sell into Ireland and the rest of the EU without appointing anyone. Its products, lawfully placed on the Northern Ireland market, move to Great Britain with unfettered access. What it must watch is the direction of its compliance: its CPSRs must assess against the EU annexes and allergen rules, its notifications go through CPNP, and if it also wants a GB Responsible Person and SCPN notification for clarity in Great Britain, those are optional additions rather than requirements. A Northern Ireland brand that has been following GB rules because it thinks of itself as British has the picture backwards.

Enforcement in Northern Ireland

Enforcement is by the Northern Ireland district councils' environmental health and Trading Standards services applying the EU regulation, coordinated with OPSS. The practical risk for a GB brand is the same as for any EU sale: a product with no EU Responsible Person, no CPNP notification and a GB only label is non compliant in Northern Ireland, and a complaint or a marketplace check can surface it. The consequences are the same as any non compliance: a demand for documents, a requirement to withdraw, and a listing suspension in the meantime.

A worked example: the Manchester soap brand

Back to the Belfast order. The brand has a GB Responsible Person, SCPN notifications and GB labels, and Etsy is asking for an EU Responsible Person. It has three choices. It can exclude Northern Ireland from delivery, which is lawful and takes five minutes in the platform settings. It can appoint an EU Responsible Person, add CPNP notifications and move to a UK wide label. Or it can treat this as the first step of an EU expansion and do the same for Ireland and beyond. It chooses the second. It appoints an Estonian Responsible Person service, has its existing GB CPSRs extended to dual market by addendum, which takes a week and costs a fraction of new reports, reprints its labels with both addresses and the expanded allergen list at the next print run, notifies through CPNP, and updates its PIFs with the change logged. Six weeks after the Etsy message it is compliant across the whole United Kingdom, and when a customer in Dublin orders three months later, nothing further is needed.

A practical route for a GB brand selling UK wide

• Decide whether to sell into Northern Ireland at all. Some small brands exclude it rather than take on EU compliance; that is lawful if enforced at checkout.
• If yes, appoint an EU or NI Responsible Person. Before the first Northern Ireland sale.
• Have the CPSR assessed as dual market. EU annexes and allergen rules checked and stated, by addendum if you hold a GB report.
• Build a UK wide label. Both Responsible Persons, the EU allergen list.
• Notify through CPNP. In addition to SCPN.
• Keep two PIFs, or one file with both markets' documents. Held by each Responsible Person.
• Log the market in the change log. And review both regimes annually.

Myths we hear

• Northern Ireland is the UK, so UK rules apply. It is the UK, and EU cosmetics rules apply.
• My GB Responsible Person covers it. Only an EU or NI established one does.
• SCPN covers the whole UK. It covers Great Britain; Northern Ireland is CPNP.
• The allergen changes are an EU thing that does not affect me. They apply in Northern Ireland on the EU dates.
• Etsy made a mistake asking for an EU RP. Etsy applied the Framework.

What to do this week

• Check your checkout and marketplace settings for Northern Ireland delivery.
• Decide: exclude, or comply.
• If comply, contact an EU Responsible Person service and your assessor about a dual market addendum.
• Plan the UK wide label for the next print run.
• Add Northern Ireland to your PIF change log as a market.

Brands that are already selling into the EU find Northern Ireland adds nothing new; the EU compliance covers it. Brands that are GB only should decide deliberately, and a consultation will scope what the addition involves for a specific range. The next Belfast order can be the easiest one you ever pack.

Official sources and legislation

• The Windsor Framework (UK Government collection)
• Regulation (EC) No 1223/2009 on cosmetic products
• Cosmetic Products Enforcement Regulations 2013
• Cosmetic Products Notification Portal (CPNP)
• Submit cosmetic product notifications (SCPN)
• OPSS guidance on cosmetic products regulations

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.