Exporting Cosmetic Chemicals from UK to Europe: REACH Guide

Exporting cosmetic chemicals from the UK to Europe now means navigating two completely independent regulatory systems. Since 1 January 2021 the EU no longer recognises UK REACH registrations and UK authorities no longer accept EU REACH decisions, so a UK exporter must hold a valid EU REACH registration through an EU legal entity or an Only Representative to place substances on the EU market. At the same time the Cosmetic Products Regulation adds a separate layer of obligations for finished goods, including notification and Responsible Person appointment. This guide explains how to classify your products correctly, when the Annex V exemption applies, how to manage dual CLP classification and Safety Data Sheets, and what structural steps such as Only Representative appointments are required to maintain uninterrupted market access.

Exporting Cosmetic Chemicals from UK to Europe: Key Regulatory Changes Post-Brexit

The key regulatory changes for exporting cosmetic chemicals from UK to Europe after Brexit centre on the complete separation of UK and EU legal frameworks. Since 1 January 2021, the EU no longer recognises UK REACH registrations, and UK authorities no longer accept EU REACH decisions. This means a UK exporter must now hold a valid EU REACH registration, either directly through an EU legal entity or via an Only Representative, to place substances on the EU market. Simultaneously, EU manufacturers supplying the UK must comply with UK REACH. The divergence creates dual compliance costs and administrative burdens that did not exist during the transition period. European retail sales of cosmetics and personal care products were valued at €110 billion in 2025, according to Cosmetics Europe, underscoring the commercial importance of maintaining uninterrupted market access.

End of mutual recognition for chemical registrations

The end of mutual recognition for chemical registrations means that a registration dossier submitted to the European Chemicals Agency (ECHA) before Brexit no longer provides legal cover for the UK market, and a UK REACH registration does not grant access to the EU. Companies that previously relied on a single EU-wide registration must now maintain two separate dossiers, each compliant with the respective regulation. This includes separate inquiry processes, data sharing negotiations, and fee payments. The practical impact is that a UK exporter without an EU legal entity must appoint an Only Representative established in the EU to take on the registrant obligations under EU REACH.

Separate legal entities required for UK REACH and EU REACH compliance

Separate legal entities are required for UK REACH and EU REACH compliance because each regulation mandates that the registrant or Only Representative be established within the respective jurisdiction. A UK-registered company cannot submit a registration directly to ECHA; it must use an EU-based Only Representative or create an EU subsidiary. Conversely, an EU company exporting to the UK needs a UK-based Only Representative or UK entity. This structural requirement affects contract drafting, liability allocation, and data ownership. Many UK exporters have established Irish or Dutch subsidiaries to serve as the EU registrant, while EU brands often appoint UK-based consultants as their UK Only Representative.

Transition periods and grandfathering deadlines for existing registrations

Transition periods and grandfathering deadlines for existing registrations provided limited relief but have now largely expired. Under UK REACH, companies holding EU REACH registrations before 1 January 2021 could "grandfather" them into UK REACH by notifying the Health and Safety Executive (HSE) and paying a fee by the initial deadline of 27 October 2021, with full data submission required within two, four, or six years depending on tonnage band. For EU REACH, UK-based Only Representatives lost their status on 1 January 2021, forcing an immediate switch to an EU-based representative. Missing these deadlines means the substance cannot legally be placed on the market until a new registration is completed.

Aspect	EU REACH	UK REACH	Impact on Exporter
Registrant location	Must be established in EU/EEA	Must be established in UK	Requires separate legal presence or Only Representative in each jurisdiction
Agency	European Chemicals Agency (ECHA)	Health and Safety Executive (HSE)	Two submission portals, two fee schedules, two inquiry processes
Grandfathering deadline	Not applicable (UK entities lost access)	Notification by 27 Oct 2021; data submission over 2-6 years	Missed deadline = no legal supply until new registration
Data ownership	EU REACH data sharing rules apply	UK REACH data sharing rules apply	Letter of access needed for each regime; data cannot be automatically transferred

The table above summarises the structural divergence between the two regimes. A UK exporter must budget for dual registration fees, maintain two safety data sheet versions aligned with each CLP regulation, and monitor two separate candidate lists for substances of very high concern. The administrative overhead is significant for SMEs, which often lack in-house regulatory affairs teams and rely on external consultants to manage both dossiers.

Understanding REACH: EU vs UK Legal Frameworks for Cosmetic Ingredients

EU REACH and UK REACH differ for cosmetic ingredient suppliers in three critical areas: the regulatory agency and submission portal, data access mechanisms, and the obligation to appoint an Only Representative for non-resident companies. While the core principles of registration, evaluation, authorisation, and restriction remain similar, the operational details have diverged since 1 January 2021. The United Kingdom cosmetics and personal care market was worth €14.7 billion, the second biggest in Europe, according to Cosmetics Europe, making compliance with UK REACH a commercial necessity for any supplier targeting British brands or contract manufacturers.

ECHA vs HSE roles and submission portals

ECHA vs HSE roles and submission portals define where and how dossiers are submitted. EU REACH dossiers go through REACH-IT, ECHA's online platform, which handles registration, inquiry, data sharing, and communication with member state competent authorities. UK REACH dossiers are submitted via the HSE's "Comply with UK REACH" digital service. The two portals do not communicate. A substance registered in REACH-IT has no legal status in the UK system, and vice versa. This means separate IUCLID dossier preparation, separate fee payments, and separate tracking of evaluation decisions. The HSE also operates a different fee structure, generally lower for low tonnage bands but with distinct payment schedules.

Data access and letter of access requirements for UK companies

Data access and letter of access requirements for UK companies create a practical hurdle when the original EU REACH registration was held by an EU consortium or lead registrant. After Brexit, UK companies lost automatic access to the joint submission data stored in REACH-IT. To register under UK REACH, a UK company must negotiate a letter of access with the data owner, often the same EU consortium, and pay for the right to refer to those studies. The same applies in reverse: EU companies grandfathering into UK REACH may need letters of access from UK data holders. These negotiations can delay registration by months and add unexpected cost, especially for substances registered under the "one substance, one registration" principle where the lead registrant is unwilling to share.

Only Representative (OR) appointment obligations for non-EU/UK entities

Only Representative (OR) appointment obligations for non-EU/UK entities are mandatory under both regimes. A UK exporter without an EU legal entity must appoint an EU-based Only Representative to fulfil EU REACH registrant duties, including dossier submission, updates, and communication with ECHA. The OR must be established in the EU/EEA and formally accept the role in writing. Similarly, an EU manufacturer exporting to the UK must appoint a UK-based Only Representative. The OR assumes legal liability for compliance, so the contractual relationship must clearly define data ownership, confidentiality, and termination terms. Many UK exporters use specialist regulatory consultancies in Ireland, Germany, or the Netherlands as their EU OR.

Feature	EU REACH	UK REACH	Practical Consequence
Competent authority	ECHA (Helsinki)	HSE (Bootle)	Separate helpdesks, guidance documents, and enforcement policies
Submission portal	REACH-IT	Comply with UK REACH	Two IUCLID dossiers; no data transfer between portals
Only Representative location	EU/EEA established	UK established	Must appoint two different ORs if no local entity exists
Data sharing mechanism	SIEF via REACH-IT	UK SIEF via HSE portal	Separate letter of access negotiations; double cost risk
Candidate list (SVHC)	ECHA candidate list	UK candidate list (diverging)	Must monitor both lists for authorisation and restriction triggers

The comparison table highlights that the two regimes now operate as parallel but independent systems. A cosmetic ingredient supplier exporting to both markets must maintain two complete regulatory dossiers, track two candidate lists for substances of very high concern, and ensure safety data sheets reflect the correct classification under each CLP regulation. The divergence in candidate lists is particularly relevant for cosmetics, where ingredients like certain preservatives or UV filters may be listed as SVHCs in one jurisdiction but not the other, triggering different communication obligations down the supply chain.

Do Cosmetic Chemicals Need REACH Registration? The Annex V Exemption

Cosmetic ingredients are exempt from REACH registration when they are used exclusively in finished cosmetic products regulated under Regulation (EC) No 1223/2009, as specified in REACH Annex V, point 10. This exemption applies because the Cosmetic Products Regulation imposes its own rigorous safety assessment and notification requirements via a regional B2B directory, which the EU legislator considers equivalent to REACH registration for consumer protection. However, the exemption is strictly conditional on the substance having no other industrial or professional end-uses outside the cosmetic scope. If a chemical ingredient is also sold for use in detergents, industrial cleaners, or pharmaceutical formulations, the exemption falls away and full REACH registration becomes mandatory for those non-cosmetic tonnages. European cosmetic products exports had a value of €29.8 billion in 2025 according to Cosmetics Europe, illustrating the massive volume of ingredients moving under this specific regulatory carve-out.

Scope of Annex V exemption for cosmetic end-use

The Annex V exemption covers substances and mixtures intended solely for incorporation into cosmetic products as defined by Article 2 of Regulation 1223/2009. This includes raw materials like preservatives, UV filters, colorants, and fragrance compounds provided they are supplied exclusively to cosmetic manufacturers or formulators. The supplier must be able to demonstrate through supply chain contracts and technical documentation that the substance does not enter any other downstream use. If a single substance serves dual purposes, for example, a preservative used in both cosmetics and household cleaning products, the registration obligation triggers for the total tonnage manufactured or imported, not just the non-cosmetic fraction.

Conditions where full registration is still required

Full REACH registration is required when a substance exceeds one tonne per year per legal entity and the Annex V conditions are not met. This occurs if the ingredient is supplied to formulators who produce non-cosmetic goods, or if the exporter cannot guarantee exclusive cosmetic use throughout the supply chain. Additionally, substances listed in REACH Annex XIV (Authorisation List) or Annex XVII (Restrictions) retain their specific obligations regardless of the cosmetic exemption. For example, a UV filter restricted under Annex XVII entry 51 must comply with concentration limits and labelling rules even if registration is waived. Safety Data Sheets (SDS) must still be provided downstream under REACH Article 31 for hazardous substances, maintaining the communication chain for safe handling.

Intermediate use and export-only registration options

If a cosmetic chemical is manufactured in the UK and exported to the EU strictly as an intermediate under strictly controlled conditions, the registrant may opt for reduced registration requirements under REACH Articles 17 or 18. This applies when the substance is chemically converted into another substance during cosmetic formulation, such as a precursor reacting in situ. For UK exporters shipping solely to the EU without a domestic EU market presence, the "export-only registration" route allows the EU importer to fulfil the registration duty via a Downstream User Import Notification (DUIN) or by appointing an Only Representative. This avoids the UK exporter needing an EU legal entity for registration purposes, though the Only Representative must be established in the EU and hold a valid REACH-IT account.

Classify Your Product: Raw Chemicals vs Finished Cosmetics

Correct classification determines whether your export falls under REACH as a substance or mixture, or under the Cosmetic Products Regulation (CPR) as a finished good. A raw chemical ingredient, such as titanium dioxide powder or a bulk surfactant, is a substance or mixture subject to REACH registration, CLP classification, and SDS requirements. A finished cosmetic product, defined by CPR Article 2 as any substance or mixture intended to be placed in contact with external parts of the human body for cleaning, perfuming, changing appearance, or protecting, is exempt from REACH registration but triggers notification and Responsible Person appointment. Skin care is the biggest European cosmetics category, valued at €32.3 billion in 2025 according to Cosmetics Europe, and the vast majority of cross-border trade in this segment moves as finished goods rather than raw ingredients.

Legal definitions under REACH vs Cosmetic Products Regulation

REACH defines a substance as a chemical element and its compounds in the natural state or obtained by any manufacturing process, while a mixture results from mixing two or more substances. The CPR defines a cosmetic product by its intended use and site of application on the human body. The critical distinction is that REACH regulates the chemical identity and hazard profile of the ingredient itself, whereas CPR regulates the safety of the final formulation for human health. A bulk shipment of hyaluronic acid powder is a REACH substance; the same hyaluronic acid blended into a jarred cream with preservatives, emulsifiers, and fragrance is a CPR cosmetic product. Misclassification leads to missing notification or omitted REACH registrations, both carrying enforcement penalties.

Impact on Responsible Person and notification duties

For raw chemicals, the EU importer or Only Representative handles REACH registration and CLP notification to the Classification and Labelling Inventory. No Responsible Person (RP) under CPR is required because the goods are not cosmetic products. For finished cosmetics, the RP, established in the EU, must notify the product via a regional B2B directory before placing it on the market, compile the Product Information File (PIF), and ensure compliance with Annex II to VI substance restrictions. The RP also fields competent authority inspections and consumer complaints. A UK exporter shipping finished cosmetics must appoint an EU RP via written mandate; shipping raw chemicals requires an Only Representative for REACH if the UK exporter acts as non-EU manufacturer. These are distinct legal appointments with different liability scopes.

Borderline cases: bulk semi-finished mixtures

Bulk semi-finished mixtures, such as a pre-mixed emulsion base shipped to a contract filler for final packaging, create classification ambiguity. If the mixture is labelled and intended solely for further processing into a specific cosmetic product with no consumer exposure, it remains a REACH mixture requiring SDS and CLP compliance. If the mixture is already a final formulation merely awaiting packaging, it qualifies as a cosmetic product under CPR and requires notification by the RP. The deciding factors are the commercial description on the invoice, the technical specifications agreed with the buyer, and whether the mixture meets the CPR definition of "intended to be placed in contact with the human body." Contracts should explicitly state the regulatory status to avoid dual compliance gaps or duplicate obligations.

Compliance with CLP and Safety Data Sheets (SDS)

EU CLP Regulation alignment and UK divergence points

The EU CLP Regulation (EC) No 1272/2008 remains the legal baseline for classifying, labelling and packaging cosmetic chemicals exported from the UK to the EU. Great Britain operates GB CLP which mirrors the EU text but diverges where the Health and Safety Executive (HSE) sets independent mandatory classification and labelling (MCL) entries or adopts ATPs on a different timetable. Exporters must classify substances against both lists because a substance may carry a harmonised classification in the EU that GB has not yet adopted or vice versa. The label on the inner packaging must display EU hazard pictograms signal words and hazard statements in the language of the destination member state. Outer transport packaging follows ADR rules but must still show the EU CLP label elements when the inner pack is not visible during transit. A single safety data sheet can serve both regimes only if it clearly distinguishes EU and GB classification outcomes in Section 2 and Section 15.

Mandatory SDS sections for cosmetic raw materials

Every cosmetic raw material shipped to the EU requires a 16-section SDS compliant with REACH Annex II as amended by Regulation (EU) 2020/878. Sections 1 to 3 identify the substance or mixture the supplier and the hazard classification. Section 8 must list occupational exposure limits including any EU indicative occupational exposure limit values (IOELVs) and biological limit values. Section 9 requires physical and chemical properties relevant to cosmetic processing such as pH flash point and particle size distribution for powders. Section 11 must summarise toxicological data including skin sensitisation and eye irritation endpoints used for CPSR toxicological profiling. Section 12 covers ecotoxicity and biodegradability data required for the environmental risk assessment under the Cosmetic Products Regulation. Section 14 states the UN number proper shipping name and transport hazard class. Section 15 must reference the specific Annex II III IV V or VI entries under the Cosmetic Products Regulation that apply to the ingredient.

Language requirements for SDS in destination member states

The SDS must be supplied in an official language of the member state where the substance or mixture is placed on the market. If a UK exporter ships to a distributor in Germany the SDS must be in German; if the same goods move to a filler in France a French version is mandatory. The supplier is responsible for translation accuracy particularly for hazard statements precautionary statements and the substance name in Section 1. Machine translations are not accepted by enforcement authorities. The SDS must be provided free of charge on paper or electronically no later than the first delivery. Updates triggered by new classification information or revised exposure limits must be sent to all recipients who received the substance within the preceding twelve months. A practical workflow is to maintain a master English SDS and engage a specialist regulatory translator for each target market language before the first shipment.

Navigating Prohibited and Restricted Substances (Annex II & III)

Annex II prohibited substances list verification

Annex II of Regulation (EC) No 1223/2009 lists over 1700 substances that must not form part of the composition of cosmetic products placed on the EU market. Verification starts by screening the full ingredient INCI name and CAS number against the current consolidated Annex II published on the European Commission cosmetic ingredients database (CosIng). Impurities that are Annex II substances are permitted only if they are technically unavoidable under good manufacturing practice and the finished product passes the safety assessment. The responsible person must document the impurity profile in the product information file. A practical control is to require the raw material supplier to provide a certificate of analysis stating the Annex II impurity levels for each batch. Any reformulation of a cosmetic chemical blend must trigger a fresh Annex II screen before export.

Annex III restricted substances concentration limits

Annex III sets maximum authorised concentrations for approximately 300 restricted substances in finished cosmetic products. The limits apply to the substance as used in the final formulation not to the raw material as supplied. Exporters of cosmetic chemicals must provide the downstream formulator with the exact concentration of each Annex III substance in the raw material so the formulator can calculate compliance in the finished product. Typical restricted entries include preservatives such as phenoxyethanol limited to 1.0 percent and fragrance allergens such as limonene with specific declaration thresholds. The raw material SDS Section 3 should disclose the concentration range of every Annex III component. If a raw material contains a restricted substance above the finished product limit the formulator must dilute it accordingly. The responsible person verifies the final calculation in the cosmetic product safety report.

Annex VI colorants preservatives and UV filters positive lists

Only colorants preservatives and UV filters listed in Annexes IV V and VI respectively may be used in cosmetic products sold in the EU. Each entry specifies the substance name the field of application and the maximum authorised concentration. For colorants the CI number and purity criteria are mandatory. Exporters supplying these positive-list substances must ensure the grade shipped meets the purity specifications such as heavy metal limits for colorants or isomer ratios for UV filters. The certificate of analysis must reference the relevant Annex entry number. If a substance appears on multiple annexes the strictest condition applies. New positive-list entries are added by commission regulation; exporters should monitor the CosIng database and the Official Journal for updates that could open or close market access for specific chemical grades.

Annex	Category	Number of Entries	Key Compliance Document	Typical Limit Type
Annex II	Prohibited Substances	1700+	CosIng Database Screening Report	Zero tolerance (technically unavoidable impurities excepted)
Annex III	Restricted Substances	~300	Certificate of Analysis with Concentration Ranges	Maximum concentration in finished product
Annex IV	Colorants (Positive List)	150+	Certificate of Analysis with CI Number and Purity	Maximum concentration in finished product
Annex V	Preservatives (Positive List)	60+	Certificate of Analysis with Purity Criteria	Maximum concentration in finished product
Annex VI	UV Filters (Positive List)	30+	Certificate of Analysis with Isomer Ratio	Maximum concentration in finished product

The table summarises the five regulatory annexes that control substance compliance for cosmetic chemicals entering the EU. Annex II operates as a negative list with zero tolerance for intentional use. Annexes III through VI function as positive or restricted lists where the exporter must prove the substance identity purity and concentration match the authorised entry. The certificate of analysis is the primary evidence for customs and the responsible person. Each batch shipped should carry a CoA referencing the specific annex and entry number. The responsible person uses these documents to complete the product information file and the cosmetic product safety report before the notification.

Appointing Responsible Persons (EU RP and UK RP)

RP mandate applies only to finished products under Article 4 CPR

The EU Responsible Person requirement under Article 4 of the Cosmetic Products Regulation applies strictly to finished cosmetic products placed on the EU market. Raw chemical ingredients or intermediate mixtures sold B2B for further formulation do not require an EU RP appointment by the exporter. The legal obligation to designate an RP falls on the entity that makes the finished product available to the end consumer in the EU, typically the importer or the brand owner. UK exporters of raw materials should verify whether their EU buyer intends to act as the RP or has appointed a third-party consultant. If the UK exporter also sells finished goods directly to EU consumers or retailers, they must appoint an EU-based RP before the first placement on the market.

Importer obligations for raw chemicals under REACH Article 8

For raw cosmetic chemicals, the EU importer assumes duties under REACH Article 8 as the "importer of substances." This role requires the importer to ensure registration compliance for substances above one tonne per year unless an exemption applies. The UK exporter must provide the importer with a compliant Safety Data Sheet and substance identity information sufficient for the importer to fulfil their registration or inquiry obligations. Contractual terms should clarify who holds the REACH registration or whether the substance benefits from the Annex V exemption for naturally occurring substances. The importer must also verify classification and labelling compliance under CLP before the goods clear customs.

Contractual liability and representation agreements

A written mandate between the UK exporter and the EU Responsible Person or importer defines liability allocation for regulatory non-compliance. The agreement should specify which party maintains the Product Information File, handles notification, and manages market surveillance inquiries. For raw material supply, the contract must address SDS updates, change management for substance composition, and the obligation to communicate SVHC presence above 0.1 percent weight by weight. UK exporters retaining an EU RP for their own finished goods should ensure the RP holds a valid mandate and has access to the complete safety assessment. Without a clear agreement, the UK exporter risks enforcement action in both jurisdictions simultaneously.

Conclusion

Secure an EU legal entity or appoint an EU-based Only Representative before shipping any cosmetic chemical to the EU, because UK REACH registrations confer no rights in the European market. Classify every substance against the Annex V exemption strictly: if an ingredient has any non-cosmetic use, full EU REACH registration for the total tonnage is mandatory. Prepare two separate Safety Data Sheets aligned with EU CLP and GB CLP respectively, and verify whether each product requires REACH registration, cosmetic product notification, or both.

Negotiate letters of access for any joint submission data you rely on, since data does not transfer between REACH-IT and the HSE portal. Monitor both the ECHA and HSE candidate lists for SVHCs that trigger supply-chain communication duties. Start by confirming your Only Representative agreement and registration status, then use Global Trade Plaza to identify and verify EU distributors or buyers for your compliant product range.

Frequently Asked Questions

Do I need REACH registration for cosmetic ingredients exported to the EU?

Cosmetic ingredients used exclusively in finished cosmetic products regulated under Regulation (EC) No 1223/2009 are exempt from REACH registration under Annex V point 10. If the substance has any non-cosmetic industrial or professional end-use, full REACH registration is required for those tonnages.

What is the difference between EU REACH and UK REACH for cosmetics?

EU REACH and UK REACH operate as separate legal regimes requiring distinct registrations, separate Only Representatives established in each jurisdiction, and independent data submissions to ECHA and the HSE respectively. Diverging candidate lists and restriction timelines create dual compliance obligations for cosmetic ingredient suppliers.

Can I use an EU Responsible Person for UK exports?

No, an EU Responsible Person appointed under the Cosmetic Products Regulation covers only product safety and CPNP notification for the EU market. UK cosmetic compliance requires a separate UK Responsible Person established in Great Britain to fulfil obligations under the UK Cosmetics Regulation.

What documents are needed to ship cosmetic chemicals from UK to EU?

Required documents include a commercial invoice, packing list, transport document (CMR or bill of lading), Safety Data Sheet compliant with EU CLP, REACH registration number or Annex V exemption statement, and an EORI number for both exporter and importer. A customs declaration using the correct HS code is mandatory.

Are cosmetic ingredients exempt from REACH registration?

Cosmetic ingredients are exempt only when supplied exclusively for use in finished cosmetic products under Regulation 1223/2009 per REACH Annex V point 10. The exemption does not apply if the substance is also used in detergents, pharmaceuticals, or any non-cosmetic application.

How to classify cosmetic chemicals for customs purposes?

Classify cosmetic chemicals using the Combined Nomenclature (CN) codes under HS Chapter 33 for essential oils, perfumery, and cosmetic preparations, or Chapters 28, 29 for specific organic and inorganic chemical substances. Verify the exact code via the EU TARIC database or UK Trade Tariff to determine duty rates and import requirements.

What are the restricted substances in EU cosmetic chemicals?

Restricted substances are listed in Annexes II to VI of Regulation (EC) No 1223/2009, covering prohibited substances, restricted substances with concentration limits, permitted colorants, preservatives, and UV filters. REACH Annex XVII imposes additional restrictions on chemicals like CMR substances that may appear in cosmetic ingredients.

Do I need an EORI number to export chemicals from UK to Europe?

Yes, a UK EORI number starting with GB is required for the exporter to complete UK export declarations, and the EU importer must hold an EU EORI number for import clearance into the EU. Both numbers are mandatory for customs processing under the Trade and Cooperation Agreement.

What is the Annex V exemption for cosmetic chemicals?

REACH Annex V point 10 exempts substances used solely as ingredients in cosmetic products regulated under Regulation 1223/2009 from registration, evaluation, and authorisation. The supplier must demonstrate through contracts and technical documentation that no non-cosmetic downstream use occurs.

How long does REACH registration take for cosmetic ingredients?

Preparing a REACH registration dossier typically takes 6 to 18 months depending on data availability, SIEF negotiations, and tonnage band complexity. ECHA or HSE evaluation timelines vary; a complete dossier submitted via REACH-IT or Comply with UK REACH receives a registration number upon fee payment.

What is the role of an Only Representative under EU REACH?

An Only Representative established in the EU/EEA assumes the legal obligations of the importer for REACH registration, including dossier submission, updates, and communication with ECHA. The non-EU manufacturer retains product liability but delegates regulatory compliance to the OR via a written mandate.

How do I submit a Downstream User Import Notification (DUIN) for UK REACH?

UK downstream users importing substances from the EU without a UK REACH registration must submit a DUIN via the HSE "Comply with UK REACH" portal within 30 days of first import. The notification requires substance identity, tonnage band, use description, and confirmation that the substance is not subject to authorisation or restriction.

Sources

• Cosmetics Europe (2025): European cosmetics and personal care retail sales