If you manufacture cosmetics, hair care products or soaps in the UK, the MoCRA does not come into play immediately, but it does so only at the second step. This US legislation comes into play only when you begin to ship your product across the Atlantic Ocean. What gets many small British businesses in trouble is the fact that the UK legislation, which you need to comply with anyway, is sometimes even more stringent than MoCRA. Let’s look at what it means from the practical perspective for a business owner based in Leeds or Bristol.
Why The UK Rules Come First
Great Britain is still governed by the Retained Regulation 1223/2009 via the Cosmetic Products Enforcement Regulations 2013. The OPSS statutory guidance on GOV.UK outlines in detail what this means in reality, and I recommend checking it all out before paying for any consultants.
Three obligations are incumbent upon every product, in every business of any scale:
A UK Responsible Person. A natural or legal person established in the UK whose name and address will be printed on the product’s label is required. If you manufacture your product in the UK as a founder, you will have to assume this role yourself; if you import finished goods from overseas, it won’t – the manufacturer from abroad will have to appoint one. Here are CIRS Group’s requirements, including GMP compliance, possession of the safety assessment, and acting as a liaison between OPSS and consumers.
Cosmetic Product Safety Report (CPSR). This is where most people get confused. “Here’s the truth, ” says Phoenix Cosmetic Safety, “every cosmetic product manufactured in the UK must have a CPSR and it is illegal to sell anything without.” There is no exception made for small businesses here; the CPSR must be prepared by a competent assessor.
Transitional peculiarity that is worth noting: in accordance with the OPSS recommendations, until 31 December 2027, a seven-year period, the labeling requirement will be met in case of an indication of the name and address of the EU/EEA Responsible Person in compliance with the European regulation. This information might come in handy for sellers operating on two markets.
The Small Business Exemption — and Its Trap
According to MoCRA, companies whose average gross annual US cosmetic sales for the last three years are less than $1 million are not required to register their facilities, list products, and follow the Good Manufacturing Practices (GMP). The record of adverse events is shortened from 6 years to 3 years.
The trap: If you manufacture any of the products that come into contact with the mucous membrane of the eye, injections, internal applications or products which alter appearance for more than 24 hours, the exemption does not exist at all. As Registrar Corp states, there are no exemptions at all: selling even one non-exempt product you need to comply with all requirements of the act.
Why This Matters for UK-Based Companies
You are regulated, whether you export or not. In some ways, the UK regime is more stringent than MoCRA. There is no exception for small businesses from the CPSR requirement; according to Phoenix Cosmetic Safety, a proper safety report is a legal requirement for all products marketed in the UK. The MoCRA threshold of $1 million does not exist in the UK; therefore, if you thought that your company was exempted in the US because of that amount, you were wrong.
The enforcement is vigorous and becoming increasingly coordinated. The OPSS Product Safety Database report for 2025 to 2026 explains how Trading Standards, environmental health in Northern Ireland, and OPSS record unsafe and non-compliant products.
As reported by Clyde & Co in its 2026 regulatory outlook, when Trading Standards brings a prosecution case against someone, the penalty might consist of a fine or imprisonment for up to three months in the most severe cases and senior managers might incur personal liability if the offence was committed with their consent, connivance, or negligence. The latter becomes significant for founder-led brands, as the person signing the label is usually the one who bears the risk.
Leave a Reply