Supplying Hotel Amenities to the UK After Brexit
Great Britain runs its own cosmetics regime: products need a UK-based Responsible Person, a product information file with a safety assessment, and notification through the government's SCPN service before sale. Northern Ireland may follow EU rules instead, so check before shipping there.
Since Brexit, hotel toiletries supplied in Great Britain need a UK-based Responsible Person, a product information file with a safety assessment, English labels showing that UK Responsible Person, and notification through the UK government's Submit Cosmetic Product Notification (SCPN) service before they are supplied. An EU notification and EU Responsible Person do not cover Great Britain.
This guide is for UK hotel groups, distributors and importers buying private-label amenities from India. For the wider European picture, see our Europe hotel amenities hub and our UK hotel amenities page.
The legal basis
Great Britain kept the EU cosmetics rules at the point of exit and has amended them since. The result is a UK version of Regulation (EC) No 1223/2009, often called the UK Cosmetics Regulation, enforced by trading standards and overseen by the Office for Product Safety and Standards. The structure will feel familiar to anyone who knows the EU rules: Responsible Person, product information file, safety report, notification and labelling. The differences lie in where the Responsible Person must be based and which portal you use.
Hotel shampoo, conditioner, shower gel, 2-in-1, body lotion and hand wash are cosmetics. Supplying them free to guests as part of a paid stay is generally treated as making them available on the market.
The UK Responsible Person
Each product must have a Responsible Person established in the UK. For goods imported from outside the UK, the importer is the Responsible Person unless another UK-based person is appointed in writing. That may be:
- the hotel group, if its UK company imports the goods
- a UK distributor or hospitality supplier
- a regulatory service provider acting for the brand owner
Harrods Health is not a UK Responsible Person. We manufacture the product, print the packaging and supply the formula, INCI and manufacturing documentation the Responsible Person needs.
Product information file and safety assessment
The Responsible Person keeps a product information file for each product, including a safety report prepared by a qualified assessor. The assessor needs the quantitative formula, raw material information, stability and microbiological information, packaging details and a description of manufacturing and quality controls. We supply ingredient lists and manufacturing documentation on request, and formulas can be supplied as dermatologically tested with reports on request.
SCPN notification
Before supply, the Responsible Person notifies each product through SCPN on GOV.UK. The information broadly mirrors the EU notification: product name and category, Responsible Person details, country of origin, frame or exact formulation, and any nanomaterials or substances of concern. Each distinct product, including a separate scent, is usually notified separately. Products already notified on the EU CPNP still need their own SCPN notification for the GB market.
Labelling for the UK
Labels for Great Britain must be in English and include the UK Responsible Person's name and address, along with the usual details: country of origin for imported products, nominal content, durability date or period after opening, precautions, batch number, function where needed and the INCI ingredient list. If you sell in both the EU and GB, a shared label can carry both a UK and an EU address, but check the layout with both Responsible Persons. Our custom packaging team can manage split artwork for different markets.
| Item | Great Britain | EU |
|---|---|---|
| Responsible Person | Based in the UK | Based in the EU |
| Notification | SCPN on GOV.UK | CPNP |
| Label language | English | Set by each member state |
| Address on label | UK Responsible Person | EU Responsible Person |
| Customs number | GB EORI | EU EORI |
The Northern Ireland question
Northern Ireland sits under different arrangements from Great Britain. For goods such as cosmetics, it may follow EU rules, which would mean an EU-based Responsible Person, CPNP notification and an EU address on the label. The arrangements have changed more than once since 2021, so check the current position with your Responsible Person or adviser before you supply hotels there.
Ingredient rules may diverge
Great Britain does not automatically adopt new EU ingredient restrictions or labelling changes. Over time, the permitted ingredient lists, fragrance allergen labelling and other details may differ between the two markets. If one formula is meant to serve both, ask your safety assessor to check it against both sets of rules and plan for whichever is stricter.
Packaging and waste rules
The EU's Packaging and Packaging Waste Regulation does not apply in Great Britain, but the UK has its own measures. Extended producer responsibility for packaging and plastic packaging tax can apply to UK businesses that import filled packaging, depending on their size and role. Ask your importer or adviser how these apply to you. Many UK hotels have already moved bathrooms to dispensers with 5 L refills; see our guide to reducing single-use plastic in hotel amenities.
Shipping from India to the UK
Most orders move by sea to a major UK container port and then by road to the importer's warehouse. Points to settle early:
- Importer of record: the UK business that declares the goods and pays any duty and import VAT. It needs a GB EORI number.
- Customs broker: classifies the goods, checks the duty rate and any preference under trade agreements, and files the declaration.
- Incoterms: decide who pays freight, insurance and import charges, and where risk passes.
- Documents: commercial invoice, packing list, bill of lading and, where a preference is claimed, origin evidence.
- Pallets: wooden pallets must meet international plant-health treatment and marking rules; plastic pallets avoid the issue.
Duty rates and trade terms change, so ask your broker to confirm the position for your products before you price the range. More detail is on our fulfilment and export page.
A checklist for UK buyers
Before your first order, confirm each of these points:
- Who is the UK Responsible Person, and have they agreed in writing?
- Has a qualified assessor been briefed, and do they have the formula data they need?
- Does the artwork show the UK Responsible Person's address, English text and the final INCI list?
- Will the same products go to Northern Ireland or the EU, and if so, which extra steps apply?
- Who is the importer of record, and does it hold a GB EORI number?
- Which Incoterm applies, and who pays freight, insurance, duty and import VAT?
- Has someone checked UK packaging obligations for the importing business?
- Is SCPN notification planned to finish before the goods reach hotels?
Running these in parallel with sampling and artwork is the simplest way to avoid stock waiting in a warehouse.
Why buyers work with us
We manufacture shampoo, conditioner, shower gel, 2-in-1, body lotion and hand wash in minis, tubes, sachets, dispenser bottles and 5 L refills, and we make and decorate the packaging in-house. Our facility is GMP-compliant and ISO certified, holds a state FDA cosmetic manufacturing licence and an AYUSH licence, is US FDA registered, and we are Halal certified. See quality and certifications and browse the hotel amenities collection.
Frequently asked questions
Is an EU CPNP notification valid in Great Britain?
No. Products supplied in Great Britain need their own SCPN notification by a UK-based Responsible Person.
Can one label serve both the UK and the EU?
Often, if it carries both Responsible Person addresses and meets both sets of language and content rules. Check the layout with both Responsible Persons.
Which rules apply to hotels in Northern Ireland?
Northern Ireland may follow EU cosmetics rules. Check the current arrangements before supplying hotels there.
Who pays import duty on hotel amenities?
The importer of record, unless your Incoterm shifts the cost to the seller. Your customs broker will confirm current rates.
Supplying UK hotels? See our UK hotel amenities page or the Europe hotel amenities hub.
Related service: Hotel amenities supplier for European hotels →
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