Do You Need a Licence to Sell Skincare Products?

By Dr. Helena Vos, Regulations & Ethics | International Institute of Beauty

The UK skincare market is booming but before launching a product, it's vital to understand the legal framework that governs cosmetic sales. While a traditional “licence” isn’t required, strict compliance with UK cosmetic regulations is mandatory.

From appointing a Responsible Person to submitting your product for notification, this article outlines the essential steps you must take to legally sell skincare in the United Kingdom.

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What Legally Counts as a Skincare Product?

In UK law, skincare products fall under the category of cosmetic products, defined by the retained version of the EU Cosmetics Regulation (EC) No 1223/2009, now part of the UK Cosmetics Regulation.

A cosmetic product is:

“Any substance or mixture intended to be placed in contact with the external parts of the human body… with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours.”

This includes moisturisers, serums, toners, face masks, exfoliators, cleansers, eye creams, and facial oils.

However, if your product claims to treat or prevent a disease (e.g. eczema, acne, or rosacea), it may be reclassified as a medicinal product or medical device, which falls under an entirely different regulatory regime, requiring MHRA approval and potentially a marketing authorisation (licence).

Do You Need a Licence to Sell Skincare in the UK?

While there is no cosmetic licence in the traditional sense, you must comply with all aspects of UK cosmetic law before selling skincare products to the public.

This includes the following critical steps:

1. Appoint a UK Responsible Person (RP)

Under UK legislation, every cosmetic product sold in Great Britain must have a Responsible Person (RP) established in the UK. This individual or company is legally accountable for ensuring the product meets all safety, labelling, and compliance standards.

The Responsible Person can be:

• The UK based manufacturer (if you produce the products yourself)

• The importer (if you bring products into the UK from abroad)

• A third party compliance provider acting on your behalf

  
  

The RP’s name and UK address must appear on the product label. Without an RP, the product cannot be legally sold in the UK.

2. Complete a Cosmetic Product Safety Report (CPSR)

All skincare products must undergo a comprehensive safety assessment conducted by a qualified cosmetic safety assessor usually a chartered chemist or toxicologist.

The Cosmetic Product Safety Report (CPSR) includes:

• A full ingredient breakdown, including concentrations

• Toxicological profiles of each ingredient

• Assessment of product stability and microbiological safety

• Review of intended use and application area (e.g. face, body)

• Identification of potential risks (e.g. allergens)

  
  

This report forms part of your Product Information File (PIF) and must be completed before your product reaches the market.

3. Create and Maintain a Product Information File (PIF)

The Product Information File is a legal requirement for each individual cosmetic product and must be retained for 10 years after the last batch is placed on the market. It must be made readily available to UK enforcement authorities upon request.

The PIF must contain:

• The CPSR

• Manufacturing and GMP (Good Manufacturing Practice) documentation

• Product description

• Proof of any product claims (e.g. “hydrates skin for 24 hours”)

• Details of animal testing (if applicable)

  
  

4. Notify the Product on the UK Submit Cosmetic Product Notification Portal (SCPN)

Before placing your skincare product on the market, you must notify it via the UK SCPN portal, operated by the Office for Product Safety and Standards (OPSS).

The submission must include:

• RP details

• Product category and formulation

• Ingredients (with percentages for specific substances)

• Labelling and imagery

• Nanomaterials (if used)

  
  

Only once a product is submitted and acknowledged can it be legally marketed in England, Scotland, or Wales.

If you are selling in Northern Ireland, you must instead use the EU Cosmetic Products Notification Portal (CPNP), due to post Brexit protocol arrangements.

5. Comply with Cosmetic Labelling Requirements

Your product packaging must include the following information, clearly and legibly:

• Product function (e.g. “face moisturiser”)

• Ingredients (in INCI format)

• Nominal net contents (e.g. 50ml)

• Period After Opening (PAO) or best before date

• Precautions for use

• Batch number

• Name and address of the UK Responsible Person

• Country of origin (if imported)

  
  

All mandatory text must be in English for products sold in Great Britain.

Selling Skincare Online: Do the Same Rules Apply?

Yes, all of the above requirements apply whether you sell skincare in store, on your own website, via marketplaces like Etsy or Shopify, or through social media platforms.

Products sold online are subject to the same legal scrutiny. Sellers must be prepared to produce their PIFs, safety assessments, and evidence of SCPN notification upon request by Trading Standards or the OPSS.

Misrepresenting your products as “handmade,” “small batch,” or “natural” does not exempt you from regulation.

International Perspective: How Do UK Rules Compare?

European Union

The EU Cosmetics Regulation remains largely identical to the UK's version. The main difference post Brexit is that companies must now appoint separate Responsible Persons for the UK and EU markets and complete separate product notifications via SCPN (UK) and CPNP (EU).

United States

The US Food and Drug Administration (FDA) does not pre approve cosmetics, but manufacturers are responsible for safety. However, under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), cosmetic facilities will soon be required to register and list products with the FDA, bringing US regulations closer to UK and EU standards.

Asia Pacific

Regulations vary widely. Countries like South Korea and Japan have well developed cosmetic laws, while others are still evolving. Ingredient restrictions and labelling requirements differ, requiring region specific strategies.

Final Thoughts

While you do not need a traditional licence to sell skincare products in the UK, you must comply fully with the UK Cosmetics Regulations. This includes appointing a Responsible Person, conducting a safety assessment, maintaining a Product Information File, notifying your product on the SCPN portal, and ensuring compliant labelling.

These steps are not optional they are legal obligations designed to protect consumers and uphold industry integrity. Navigating them may seem complex, but with the right guidance and diligence, it is entirely achievable.

By prioritising compliance, you not only safeguard your business but also build trust with a growing community of informed and conscientious beauty consumers.