Selling a fragrance in Great Britain

First, decide which UK you mean

Great Britain means England, Scotland and Wales. Northern Ireland is part of the United Kingdom but stays aligned with EU cosmetics rules under the Windsor Framework, so a product sold in Belfast follows the EU list and is notified to the EU portal, while the same product sold in Cardiff does not and is not.

This matters more than a constitutional footnote should, because a great deal of guidance written by well-meaning people says UK when it means GB. When you read a rule about the United Kingdom, find out which of the two it covers before you act on it.

The rest of this page is about Great Britain. The underlying structure is the same as the European Union's, because GB copied EU law across at the end of the transition period and has amended it since. Read the EU guide for how the machine works; this page is the list of places the two have come apart.

You need a second responsible person

A GB responsible person must be established in the United Kingdom. An EU or EEA entity cannot serve as one, and a UK entity cannot serve as an EU responsible person either. The relationship is symmetric and there is no workaround.

A business selling the same perfume into both markets therefore needs two responsible persons, at two addresses, which means two label versions, because the address is printed on the label. That is a structural cost of selling into both, and it is the item most often left out of a first plan.

A separate notification, to a separate portal

GB products are notified through the Submit Cosmetic Product Notification service, run by the Office for Product Safety and Standards, rather than through the EU portal. The fields will look familiar because the service was built from the same specification, but it is a separate submission: notifying the EU does nothing for GB, and a product already on sale in France still has to be notified before it goes on sale in Wales.

The product file obligation is the same in substance. A GB responsible person holds the file, at the address on the label, and produces it on request for the same ten-year period. The safety assessment is required in the same way, and the qualification an assessor must hold is written the same way, so an assessment prepared for the EU market is usually usable, with the market-specific parts revisited.

The allergen list is where the two regimes really part

This is the largest practical divergence and the one that shows up on the carton. The European Union rewrote and lengthened its declarable fragrance allergen list, with the first obligation biting on 31 July 2026. Great Britain did not adopt that change and retains the shorter pre-2023 list.

The thresholds themselves did not diverge. GB kept the same mechanism, so an allergen is declared above 0.001 percent of a leave-on product and 0.01 percent of a rinse-off one, exactly as in the EU, and both figures are still percentages of the finished product rather than of the concentrate. What changed is the list those thresholds are applied to.

The consequence is that one label cannot be assumed to serve both markets. A GB label is short of what the EU now requires. An EU label names materials GB does not ask for, which is not itself a GB breach, so a single label carrying the longer list is a legitimate strategy. It is a decision to take deliberately, checking the GB rules on language and legibility against the longer ingredient list, and knowing that the two regimes may move again.

The direction of travel is worth watching rather than betting on. GB has been expected to consult on aligning with the expanded list, and industry advice has generally been to hold the wider data even for GB-only sales, on the reasoning that gathering allergen figures late is far more expensive than gathering them early.

Classification: a different list with the same shape

If you supply concentrate to another business rather than finished perfume to a person, you are classifying and labeling a chemical mixture, and here too GB has its own list. The GB Mandatory Classification List, published by the Health and Safety Executive, does the job the EU's harmonized Annex VI does. It began as a copy and has not tracked EU updates since, so entries can differ.

The same is true of the substances of very high concern list, which is administered separately in GB and is much shorter than the EU's. And GB did not adopt the four new EU hazard classes for endocrine disruptors and for persistent, bioaccumulative, mobile or toxic substances, so a mixture can require a classification in the EU that GB has no equivalent of.

Safety data sheets, and the UFI that is not there

A finished cosmetic supplied to a consumer needs no safety data sheet in GB, for the same reason it needs none in the EU. A mixture supplied to another business does.

GB did not adopt the EU's 2020 update to the safety data sheet format. Sixteen sections are still required and their content is substantively the same, so in practice a current EU sheet is close to a GB sheet. The visible difference is the unique formula identifier: the EU requires one on the label and in section 1 of the sheet, tied to a poison center notification. GB did not adopt that system and has no equivalent, so a GB sheet does not carry a UFI.

The differences in one table

How Orris Bench handles this

Which markets a product is sold into is a fact you state once, per product, and it can be more than one. The documents that depend on it read it rather than assuming a market, so a product sold into the EU, Great Britain and the United States produces three sets of paperwork from one formula and one batch record, without the formula being entered three times.

Orris Bench keeps the GB notification record alongside the EU one, as the separate submissions they are, rather than treating one as a copy of the other. The safety data sheet is written to the profile of the market it is for, and the compliance work behind all of it, the IFRA assessment and the allergen figures, is done once on the formula and read by each market's documents.

Sources

The GB regime is the retained version of Regulation (EC) No 1223/2009 as amended by UK statutory instruments, published on legislation.gov.uk. Notification is through the Office for Product Safety and Standards. The mandatory classification list and the GB substances of very high concern list are published free by the Health and Safety Executive under open government terms. The Northern Ireland position follows from the Windsor Framework. The EU figures are Regulation (EU) 2023/1545 and Regulation (EU) 2023/707. This page is written for people who make fragrances and it is not legal advice; check the current legislation.gov.uk and HSE texts before relying on any statement.