I. Basic Definition and Purpose of SPNP
II. Core Registration Process and Key Steps
1. Appoint a UK Responsible Person (RP)
Legal Obligation: Non-UK manufacturers must appoint a Responsible Person (RP) based in the UK, who is responsible for ensuring product compliance and handling regulatory matters.
Scope of Responsibilities: The RP must maintain the Product Information File (PIF), submit SPNP notifications, handle recall incidents, and display their name and address on the label.
Transitional Arrangement: OPSS has extended the transitional period for RP labeling requirements to December 31, 2025, after which all product labels must be updated with RP information.
2. Prepare the Product Information File (PIF)
Core Content:
Cosmetic Product Safety Report (CPSR): Includes formulation analysis, stability testing, microbiological quality assessment, etc., and must be prepared by a qualified expert.
Labeling and Packaging: Must comply with UK regulations, including the ingredient list (INCI names), usage instructions, warnings, and RP information.
Ingredient Compliance: Must exclude EU/UK prohibited substances (such as CMR substances), and note the 2025 new regulation restricting the use of methyl salicylate (transitional period until March 31, 2026)chinawto.mofcom.gov.cn.
3. SPNP Submission and Review
Online Operation: Submit product information via the SPNP platform on the OPSS website, including product name, category, ingredients, label photos, etc.
Review Period: Typically 1-2 months, depending on the completeness of materials. Once the review is passed, the product can be legally marketed.
III. Costs and Timeframes
Fee Range:
Per Registration: Approximately GBP 1,500 (excluding VAT); costs may be higher for complex products (e.g., those containing new ingredients or special claims).
Third-Party Services: CPSR preparation, testing, and RP service fees are charged separately, typically amounting to several thousand pounds.
Time Planning:
Document Preparation: 2-4 months (including testing and CPSR preparation).
Review Period: 1-2 months; it is recommended to begin the registration process at least 6 months in advance.
IV. Special Requirements and Important Notes
1. Ingredients and Testing
Prohibited Substances: The 2025 new regulation adds 64 CMR substances to the prohibited list and restricts the use of methyl salicylate in certain productschinawto.mofcom.gov.cn.
Testing Requirements:
Stability Testing: Must simulate storage conditions (e.g., high temperature, low temperature), with a cycle of approximately 3 months.
Microbiological and Preservative Challenge Testing: All products must pass testing, with more stringent requirements for maternal and infant products.
2. Labeling and Packaging
Language Requirements: Labels must be in English and include the ingredient list, shelf life, usage instructions, and RP information.
Transitional Arrangement: Existing labels may temporarily not include RP information until December 31, 2025, but must be updated before that date.
3. Third-Party Certification
Testing Laboratories: Stability, microbiological, and other tests must be conducted by UKAS-accredited laboratories.
GMP Certification: Products exported to China may apply for UK government GMP certification to exempt them from animal testing.
V. Dual Compliance After Brexit
EU and UK Dual Registration: If a product is sold in both the EU and UK markets, CPNP and SPNP registrations must be completed separately, and the formulation may need to be adjusted to comply with regulatory differences between the two jurisdictions.
Label Differentiation: Products exported to the EU must be marked "Made in UK," and vice versa.
VI. Non-Compliance Risks and Responses
Legal Consequences: Unregistered products may be removed from the market and subject to fines or criminal liability.
Dynamic Compliance: Regularly monitor regulatory changes (such as ingredient list updates) and promptly update SPNP information and PIF.
VII. Official Resources and Support
OPSS Website: Provides SPNP platform access, guidance, and the latest regulatory updates (www.gov.uk/government/organisations/office-for-product-safety-and-standards).
Industry Association: CTPA (Cosmetic, Toiletry & Perfumery Association) provides compliance consulting and training.