With the exit from the EU now firmly concluded we are still experiencing challenges with the new rules and regulations that are applicable within the UK and the new ways of doing business as a consequence of our departure.

We have continued to work closely with our brand owners for many months to ensure they meet the new UK cosmetics regulations and that their products are correctly registered on the UK’s SCPN system, managed by the OPSS. This is to ensure our end consumers are properly protected under UK legislation. We are currently working with our brand owners to ensure they have their UK Responsible Person (UK RP) details on their products and packaging effective no later than 1st January 2023.

We have complied fully with the current requirements of UK REACH but further input to this process will be required over the next few years.

Following on from our exit from the EU new legislation will be enacted by the UK government as the UK rules and regulations on cosmetics products diverge from the rules in place in the EU. This has been illustrated through the work we carried out in removing products from the UK market that contained the banned substances Lyral and Lilial. Lilial was banned in the EU in March 2022, but the UK government did not confirm the ban until later in the year despite it being agreed when the UK was still part of the EU. We have successfully managed the transition from products containing these substances to products free of these banned substances and have worked diligently with our brand owners and retail partners to streamline this process as effectively as possible.

The next piece of legislation we are working on is the Extended Producer Responsibility (EPR) requirements which will become effective in 2024. It is similar to EU laws being brought in to reduce the amount of packaging going to landfill and to improve the recyclability of packaging. We have just started our initial communication with our brands as 2024 will be upon us before we know it. We are also reviewing any potential changes to our business impacted by the Vertical Agreements Block Exemption Order 2022 which has just come into force.

We continue to work with third party specialists, including our legal and compliance advisers and our trade association the Cosmetic Toiletry and Perfumery Association (CTPA) and have developed appropriate protocols to ensure we are aware of all our obligations under UK cosmetics legislation and can communicate these requirements to our brand owners and retail partners and to put in place the necessary actions required to meet deadlines set by the relevant authorities. We remain vigilant to all the requirements of the EU cosmetics legislation as well in order to service our retail partners and end consumers in Ireland and Northern Ireland.