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The Wheels Keep Turning But How Ready Are You?

CTPA reflects on the UK beauty and personal care Industry and how Brexit, COVID-19 and the UK as a third country to the EU will impact how you do business.

Having begun the year with the exit of the UK from the European Union, the end of the year will be marked not only by the exit of the UK from the EU single market, but also by the recovery from the global pandemic which for the past months has taken over as the main priority for businesses. However, the wheels have continued to turn, despite the world health crisis, and the negotiations for the future relationship that the UK is to establish with the EU and other international parties have not come to a halt.  Similarly, the preparations by the UK regulators on the future legislative landscape have continued for areas such as cosmetics, where preserving a strict risk-based legislation grounded on scientific principles and robust safety assessments has been at the centre of CTPA advocacy efforts.

Clarity to act

UK businesses need to focus on the preparatory work to be able to successfully navigate the coming months and years. There are already actions companies can take to ensure that they are prepared for what is to come, and certain business decisions can be made; for example, conducting a review on the labelling changes that will have to be considered, looking at the changes in the roles and responsibilities along the supply chain, giving due consideration to the introduction of customs procedures when trading with the EU and ensuring the changes around notification of products are handled in advance of the final exit day. The CTPA has had continued engagement with the UK Government to ensure that the advice given is consistent with the policy work, and to support businesses in their readiness plans which now will be combined with their COVID recovery plans.  A Brexit public advice resource is available to help guide companies and this is being updated during August to detail exactly what steps companies should be taking now in advance of the UK cosmetic regulations being formalised by the UK Government.

Under negotiation

Of course, some areas remain subject to negotiation, and this is particularly important in the area of chemicals: on workforce and environmental safety and the establishment of the UK REACH (Registration, Evaluation and Authorisation of Chemicals) framework.  As an industry that currently operates primarily as downstream users, companies should take steps to ensure that chemicals, including cosmetic ingredients, used in their operations and manufacturing will remain available on the UK market after the end of the transition period (31 December 2020).

Opportunities exist

There are exciting market opportunities that could be developed from the ongoing negotiations on an international level, where markets like the US and Australia have been deemed a priority by the UK Government, action which has been welcomed by the cosmetics industry. The removal or reduction of barriers will contribute to a smoother trading relationship and businesses might find new opportunities arise as a direct result.  CTPA is working with the Department for International Trade to help ensure that the best deal possible is secured for the cosmetics chapters in these Free Trade Agreements and has a dedicated area of the members’ intranet to help companies understand the requirements to trade in key markets overseas.

Confidence for consumers

Closer to home, CTPA has developed a Customer Charter ‘Protecting us all at the Beauty Counter – Our Pledge to Consumers’ to reassure customers of the safety considerations and processes in place when shopping for beauty safely in-store.  This has been supported by the British Retail Consortium.  The Charter is underpinned by the CTPA ‘COVID-19 Guidance on In-Store Testers and Cosmetic Counters, Beauty Safe in Store’ to promote beauty being safe in store for the customer and staff.  All cosmetic products placed on the UK and EU markets must be safe and in compliance with the strict safety rules under the EU (and soon UK) cosmetic regulations.  Advice for consumers around COVID-19 myths and news can be found on the CTPA’s dedicated consumer site,

Want to find out how CTPA membership could keep your company ahead of regulatory change?  Visit the CTPA website for more details or email

Co-authored by Nicholas Shaw Núñez, Head of International Growth & Regulatory Services and Debbie Hunter, Director of Commercial Affairs, CTPA

The Red Tree is the UK’s leading international beauty brand consultancy and a powerhouse of ideas, insight and inspiration. For an informal discussion on how we might help you, please contact us.

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