Tones of Beauty UK 2026: Compliance key to securing beauty retail partnerships
Beauty brands, including those based in the Middle East, looking to enter the UK market should treat regulatory compliance as a commercial priority rather than a box-ticking exercise, with retailers and distributors expecting products to be fully compliant before agreeing to work with them.
This was according to Jasper ten Brinke, managing director and co-owner of The Regulatory Company (TRC), during a presentation at Tones of Beauty. He outlined the duties of the ‘responsible person’ under UK cosmetics regulations, which is the individual or company legally responsible for ensuring a cosmetic product complies with safety and regulatory requirements before it is placed on the market.
Compliance
Brinke said retailers and distributors expect brands to demonstrate that products are compliant, safe and properly notified before entering into commercial relationships.
He warned that products are often promoted at trade shows before completing the required compliance process, despite compliance being one of the first areas prospective partners assess.
He said: “Your partners want your products to be compliant, safe and notified. This is one of the very first questions they will be asking when looking into a commercial relationship with your brand. They want to work with you commercially. They do not want to argue on compliance and safety, and they do not want to be the responsible person in the UK for you.”
Brinke explained that UK-based brands automatically become the responsible person for products sold domestically, while overseas brands exporting into the UK leave that responsibility with the importer unless another responsible person has been appointed.
He said: “If you are a brand which is based outside of the UK and you are selling to your clients into the UK, by definition, your clients will be the responsible person. This is something they do not want, so they will want an answer from you.”
He added that appointing a responsible person also helps brands retain greater control over confidential information, as importers acting as the responsible person may require access to formulations, packaging information and other technical documentation.
Regulatory process
Brinke outlined the steps required before a cosmetic product can be placed on the UK market, beginning with gathering formulation data and safety information before moving through assessment, labelling and notification.
He said products should only proceed to final artwork and product claims once they have passed a professional safety assessment carried out by a suitably qualified assessor.
He added that once a product has been notified, it can be placed on the market immediately, but regulatory responsibilities continue throughout its lifecycle.
“For as long as your product is on the market, you have to make sure that you respond to all authority requests. Regulations change every now and then, so there is also something to keep track of. There may be changes that impact your portfolio in six months, 12 months or 18 months.”
Ten Brinke warned brands to monitor regulatory changes that could affect products already on sale, noting that products already in the supply chain must remain compliant when new rules take effect.
Supply chain
Brinke highlighted the importance of defining responsibilities across the supply chain, particularly where manufacturers, testing laboratories, consultants and suppliers are involved.
He said brands should establish clear responsibilities from the outset and discuss how technical information will be shared between partners.
He also warned that manufacturers may be reluctant to share formulation data freely, making transparency an important consideration when selecting suppliers.
Choosing a responsible person
For brands that do not want to manage responsible person obligations themselves, Ten Brinke outlined the option of appointing a specialist compliance partner.
He said this can remove legal responsibilities from UK importers while providing reassurance to distributors that an independent compliance specialist has reviewed products.
Brinke recommended choosing a partner with recognised industry qualifications, in-house expertise and the ability to manage safety assessments, claim reviews and responsible person duties through a single organisation.
He said: “We sometimes see this split over several companies. It may happen that one expert has a different opinion from another expert. It may happen that it’s unclear where the duties and responsibilities sit. It is important, if possible, to work with a single compliance partner.”
He also advised brands to choose providers with systems capable of tracking regulatory changes across entire product portfolios.
He said: “Compliance now doesn’t mean compliance in the future. We see a lot of compliance firms sending out emails saying there is an update to the regulation. That is not what we do. We update this information in our databases and have automated reports telling you in 12 months exactly which products will be impacted.”
Brinke stressed that compliance should begin at the earliest stages of product development.
He said: “It really starts with quality information about the ingredients, the composition and the documentation. If you do not have that at the start of the process, you may end up with products that are not compliant. Compliance is safe by design.”