Do I Need a Licence to Sell cosmetic in the uk? Why the Cosmetic Product Safety Report Is the Real Requirement

It is the first question almost everyone asks, and the answer is genuinely good news: no, there is no licence to sell cosmetics in the UK, no certificate to obtain, no fee to pay and no authority whose approval you must wait for. People find this hard to believe, partly because other regulated sectors work differently and partly because a small industry has grown up selling documents that imply otherwise. What Regulation (EC) No 1223/2009 as retained in UK law actually does, enforced through the Cosmetic Products Enforcement Regulations 2013, is place the responsibility on you: prove it is safe, keep the evidence, and be ready to show it. Notification through SCPN is free and takes minutes.

This article sets out what is actually required, in plain terms, for anyone about to sell their first product. It covers the four requirements and what each means, what notification is and is not, the things people believe are required and are not, who enforces and how, the insurance question, what changes if you sell abroad or through marketplaces, a worked example of a first launch done properly, and a checklist to work through before the first sale. If you have been waiting for permission to start, you can stop waiting and start preparing instead.

The four things the law actually requires

Alongside these sit a compliant label under Article 19, good manufacturing practice, and a system for recording and reporting undesirable effects. None of the four involves an application, an inspection or a fee paid to government, which is what distinguishes this regime from licensing.

What notification is, and is not

The Submit Cosmetic Product Notifications service is a database, not an approval process. The Responsible Person creates an account, enters the product name, category, the responsible person details, a frame formulation describing the composition in standardised terms, the label image and any information needed by poison centres, and submits. A reference is issued immediately. Nobody reviews the submission, nobody approves the product, and no certificate is issued. The purpose is to give poison centres information if someone is harmed and to give market surveillance authorities a view of what is on sale. The EU equivalent, CPNP, works the same way. Brands regularly delay launches waiting for a notification to be approved, which never happens because there is nothing to approve, and equally regularly assume notification means the product has been checked, which it has not.

Things people believe are required, and are not

• A cosmetics licence. Does not exist in the UK or EU.
• A cosmetic certificate or certification number. Does not exist. Anyone selling one is selling a branded document with no legal standing.
• FDA approval or its UK equivalent. The FDA does not approve cosmetics either, and the UK has no approving body at all.
• An inspection before trading. Trading Standards may visit at any time after you are trading, but nobody inspects you into existence.
• Registration with a trade body. Voluntary, sometimes useful, never a legal requirement.
• A qualification to make cosmetics. No qualification is required to formulate or manufacture; the qualification requirement applies to whoever signs the safety report.
• Insurance. Not a legal requirement, but practically essential and required by most retailers and markets.
• A specific premises approval. GMP is required; a separate premises licence is not.

Who enforces, and how

Local authority Trading Standards services and the Office for Product Safety and Standards, using powers under the enforcement regulations and Schedule 5 to the Consumer Rights Act 2015. They can enter business premises, inspect and purchase products, take samples, and require production of the Product Information File, which is the point at which the absence of a Cosmetic Product Safety Report becomes apparent. Triggers include consumer complaints, reports of reactions, market surveillance programmes targeting particular categories, and online sweeps. Market stalls and online listings are among the easiest places to inspect. Consequences scale from advice and a period to comply, through compliance and suspension notices, to seizure and prosecution for persistent or serious breaches. In practice most first time makers meet the requirements through a marketplace request or a retailer's compliance pack rather than through enforcement.

Is it legal to sell cosmetics from home?

Yes, and a great many compliant brands do. There is no requirement for commercial premises, and no premises licence for cosmetics. What is required is good manufacturing practice, which in a domestic setting means a space that can be dedicated to production while you work, cleaned and sanitised before each batch, with pets and food kept out, calibrated scales, dedicated equipment not shared with cooking, controlled storage for raw materials and finished stock, and batch records for every run. Two practical points often need checking separately from cosmetics law: your home insurance and, if you rent, your tenancy agreement, since business use may need disclosure, and your local authority may have views on deliveries and waste if volumes become significant. None of that is a cosmetics requirement, and none of it prevents a kitchen table start, which remains how most of the brands we work with began.

The insurance question

Product liability insurance is not a legal requirement for selling cosmetics, and it is nonetheless the second thing every maker should arrange after the safety report. Markets, craft fairs, retailers and many online platforms require evidence of cover before they will let you trade, and a single reaction claim without it can end a small business. Insurers will ask whether a Cosmetic Product Safety Report exists for each product, and some will decline cover or dispute a claim where one does not, which is a practical reason the two go together. Cover is priced on turnover and product type, and disclosure matters: tell the insurer what you actually make, including anything applied to broken skin, used on children or containing actives, because a policy obtained on an inaccurate description may not respond when needed.

What changes if you sell abroad or through marketplaces?

Selling into the EU, including Ireland, requires a Responsible Person established in the EU or Northern Ireland, a notification through CPNP, and a safety report assessed against the EU annexes, which have diverged from Great Britain’s since 2021. In practice this means working to two sets of rules at once: the UK cosmetics regulations that apply at home and the eu cosmetics regulation that governs sales across the EU. Each sets its own list of permitted cosmetic ingredients, so a formula that passes in one market needs checking against the other. Selling to the United States brings MoCRA requirements including facility registration, product listing, a US contact and a US format label. Selling through online marketplaces adds no legal requirements but adds practical ones: platforms increasingly request the safety report before listings go live or when a complaint arrives, and suspend listings where documents cannot be produced. Selling through retailers brings their own compliance packs, which typically ask for the report, the file contents and an insurance certificate at a stated level. The reason all of this is asked for is consumer safety, and it is also why platforms want evidential support rather than a bare assurance that a product is compliant. None of these replaces the four requirements; each adds to them.

What about selling at markets, fairs and pop ups?

Nothing changes legally, and a few things change practically. The four requirements apply to a stall exactly as to a shop, and market organisers increasingly ask for evidence before allocating a pitch: typically public and product liability insurance certificates, and sometimes confirmation that safety assessments exist. Local authority Trading Standards officers visit markets routinely, partly because it is efficient and partly because markets are where new makers appear, and a visit usually begins with an officer picking up a product and reading the label rather than asking for paperwork. That makes labelling the most visible part of your compliance at a stall: an officer can see immediately whether there is a name and address, a batch code, an ingredient list and durability information. Carrying a folder with your reports, notification references and insurance certificate turns a potentially awkward conversation into a short one, and several makers we work with keep a slim version under the table for exactly that reason. The same folder should show how you would handle a serious undesirable effect if a customer reported one, since a serious undesirable effect is something the Responsible Person has a duty to pass on to the authorities.

A worked example: a first launch done properly

A maker plans three products for a Christmas market: a lip balm, a body butter and a bath bomb. In September she finalises the formulas and gathers supplier documents including IFRA certificates and allergen statements with percentages. In early October she submits everything for assessment; the lip balm and body butter are anhydrous and need no laboratory testing, and the bath bomb is assessed as a rinse off product used once. The reports come back within a week, with a fragrance cap on one product and a list of allergens to declare on all three. She builds Product Information Files, registers for SCPN as her own Responsible Person, notifies all three products and receives references the same day, designs labels carrying her name and address, the ingredient lists with declared allergens, batch codes, periods after opening, the required warnings and net contents, and arranges product liability insurance. Had she also planned to sell in Ireland, the same three eu cosmetic products would have needed an EU Responsible Person and a CPNP notification, because cosmetic products placed on the EU market fall under the eu cosmetic products regulation rather than the UK one. Total elapsed time about four weeks, most of it waiting for supplier documents, and total cost a few hundred pounds. She is trading lawfully at her first market, which is a more comfortable position than the stall beside her.

What if you have already been selling without these?

It is a common position and it is recoverable, provided it is addressed rather than hoped away. The practical sequence is to stop taking new orders if you can afford to, or at minimum to prioritise the highest volume product, and commission assessments for everything you sell. Existing stock is the awkward part: a product already manufactured with a non compliant label can often be over stickered with the missing elements rather than scrapped, which an assessor will advise on once the report identifies what is required. Notify once the reports exist. Build the files. If a customer has already reported a reaction, record it and keep the record, because a vigilance log starting from the day you learned of the requirement is far better than none. Brands sometimes ask whether coming into compliance draws attention to past non compliance; in our experience regulators are concerned with the current position and with cooperation, and a business that has put things right is in an entirely different conversation from one that has not.

A checklist before your first sale

• A Cosmetic Product Safety Report for every product, signed by a named qualified assessor.
• A Product Information File per product, at the address on your label.
• A Responsible Person identified, which may be you if UK established.
• SCPN notification submitted and the reference recorded.
• Labels carrying every Article 19 element and the Part B warnings.
• Batch records for every production run.
• Good manufacturing practice in your production space.
• Product liability insurance in place. 
• A complaints log ready to record any reaction.

Myths we hear

• You need a licence to sell skincare. No licence exists.
• There is a certificate you can display. There is not; anyone selling one is selling nothing of legal standing.
• Notification means the product has been approved. It is a database entry; nothing is reviewed.
• Handmade or hobby production is exempt. There is no exemption by size, method or turnover.
• You can sell while the paperwork is being sorted. All four requirements must be in place before the first sale.

What to do this week

• Stop looking for a licence; there is none to find.
• List your products and get quotations for the safety reports.
• Decide whether you can be your own Responsible Person.
• Register for SCPN so the account is ready.
• Arrange product liability insurance quotations.
• Write your launch date down and count back four weeks. Supplier documents, not the assessment, are what usually set the pace for a first launch.

The absence of a licence is not the absence of regulation; it is a different kind of regulation, where you decide when you are ready and carry the responsibility for that decision. That is how the UK cosmetics regulation works: it relies on the business to prove its own compliance rather than on a regulator to grant permission, and it expects you to report any serious undesirable effects to the authorities if they occur. Doing the four things properly is what makes that decision a comfortable one.

Related reading on the Spectra blog

•  What is a Cosmetic Product Safety Report? The complete guide
•  CPSR, PIF or TRA: which document does my product need?
•  How a Cosmetic Product Safety Report sets the period after opening
•  All Spectra articles

Spectra services mentioned in this article

• The Complete Compliance Pack: CPSR, PIF, SDS and SCPN or CPNP (£295)
•  CPSR services by product type
•  PIF services
•  UK SCPN Product Notification (from £15)
•  UK and EU Responsible Person
•  Contact Spectra

Official sources and legislation

• Regulation (EC) No 1223/2009 on cosmetic products
•  Cosmetic Products Enforcement Regulations 2013
•  Submit cosmetic product notifications (SCPN)
•  OPSS guidance on cosmetic products regulations
•   Office for Product Safety and Standards

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.