Brexit – Where are we heading to? – Regulatory impact assessment of the different BREXIT options on the cosmetics industry


Bloom Regulatory, London, United Kingdom


This article is an overview of the different BREXIT options currently being discussed and their impact on the cosmetics industry. The success of the UK and the EU cosmetics industry has relied over the years on a tariff-free and barrier-free market. The scope of the UK/EU future relationship will therefore determine the type of barriers the cosmetics industry will have to face. In order to protect business continuity, companies need to understand the challenges and opportunities of BREXIT, and have a strategy in place. This article provides an assessment of the current BREXIT options discussed in the UK from the no-deal scenario to the ‘Common Market 2.0’ proposals.


Two years after triggering Article 50 of the Treaty on European Union (TEU), there is still no consensus in the UK on what the relationship with the EU should look like post BREXIT. Industry relies on regulatory certainty to operate effectively and therefore has been suffering from lack of clarity. Businesses are finding BREXIT scenario planning a difficult exercise as so much remains unknown. In addition to the political landscape, cosmetics businesses are facing specific challenges as the sector:

  • is highly regulated (directly via the EU Cosmetics Regulation (EC) No. 1223/2009 – Thereafter ‘the EU Cosmetics Regulation’ - and indirectly e.g. Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals – Thereafter ‘EU REACH’)
  • covers a high volume of fast moving goods; 
  • has been operated via an EU integrated supply chain, and
  • includes a majority of SMEs with limited resources and staff.

In order to protect business continuit ...