Private Label Cosmetics and Skincare from China: UK Compliance and Launch Guide (CPSR, Responsible Person, SCPN)

1. Who this guide is for

This guide is written for UK businesses that want their own brand on the product, rather than reselling someone else's. Typical readers include:

• New beauty and skincare brands launching a first range of three to six products.
• Salons, spas and aesthetics clinics that want a retail line with their own name on it.
• Amazon, Shopify and TikTok Shop sellers moving from generic stock to their own brand.
• Established brands that want a second factory to compare price and quality.

If you are selling into Northern Ireland as well as Great Britain, note that the GB guidance does not cover Northern Ireland, where the Responsible Person must be established in Northern Ireland or the EU. Plan for that from day one if NI or EU sales are on your roadmap.

2. Stock formula or custom formula

Most Chinese cosmetics factories offer two routes. Which one you choose affects cost, speed and how much paperwork the factory needs to hand over.

Whichever route you take, check every ingredient against the UK restricted and prohibited lists before you pay for samples. Colourants, preservatives and UV filters can only be used if they appear on the permitted lists, as the GOV.UK cosmetics guidance explains. A formula that is legal in China is not automatically legal in the UK.

3. MOQs and lead times

Minimum orders vary widely by product type and by whether the packaging is stock or custom. As a rough guide from the factories we work with:

• Stock formula in stock packaging: often the lowest MOQs, sometimes a few hundred to a thousand units per product.
• Printed or custom packaging: the packaging supplier's MOQ is often higher than the filling MOQ, so the box or tube usually sets your minimum.
• Sheet masks and sachets: usually higher unit MOQs but a low cost per unit.

Lead times for a first order are typically several weeks for samples and several more for bulk production, plus sea or air freight. Treat these as planning ranges, not promises, and confirm each one in writing with the factory. Chinese New Year closes most factories for two to four weeks, so do not plan a bulk run across that period.

4. Packaging, including glass jars and duty

Packaging is part of your safety assessment, not just your branding. The CPSR has to consider what the product is packed in, because some materials interact with formulas. Ask the factory for the material specification of every jar, pump, dropper and tube.

Glass is a particular cost risk right now. Since 9 September 2026, glass containers of a kind used for packing goods from China, including jars, bottles and their glass closures under heading 7010, have carried a provisional anti-dumping duty with a residual rate of 52.97%, with lower company-specific rates for some named exporters. Check the exact commodity code and rate for your packaging on the UK Trade Tariff before you commit.

Two practical points. First, duty applies to the goods as declared at import, so whether a filled jar is classified as the cosmetic or the container matters; ask your customs broker. Second, if you only need glass for its look, compare PET, PETG or acrylic alternatives, or source the glass from outside China. Our UK import duty guide explains how duty and VAT are worked out.

5. The UK Responsible Person

Every cosmetic product made available to consumers in Great Britain must have a Responsible Person. According to GOV.UK, this can be a business or an individual, and it must have a UK established address. Mail forwarding and PO box addresses do not count.

For a private label brand, the Responsible Person is usually you, as the importer and the brand owner, or a specialist company you appoint. The Responsible Person must:

• Know every ingredient and the restrictions that apply to them.
• Keep an up-to-date Product Information File (PIF).
• Make sure labelling and instructions are clear.
• Notify OPSS before the product goes on sale.
• Report serious undesirable effects to OPSS.
• Be able to prove the claims made in marketing.

Your Chinese factory cannot be your GB Responsible Person, because it has no UK address. Decide early whether you will take on the role yourself or pay a specialist to do it.

6. The CPSR and Product Information File

Before a cosmetic product is sold, its safety must be checked by a qualified safety assessor, someone with a degree in pharmacy, toxicology, medicine or a similar discipline. The result is the Cosmetic Product Safety Report, which has two parts:

• Part A, safety information: ingredients and concentrations, physical and chemical properties, stability, microbiological quality, preservation, impurities, packaging and expected exposure. You supply this, mostly from factory data and test reports.
• Part B, safety assessment: the assessor's conclusions, warnings, reasoning and their name and qualifications.

The CPSR sits inside the Product Information File, which must be kept in English with a product description, the safety report, evidence of good manufacturing practice and proof of any claimed effects. GOV.UK says the PIF must be kept for 10 years after the last batch was made available. Good manufacturing practice is commonly shown through ISO 22716, so ask your factory whether it holds that certification and for a copy of the certificate.

7. SCPN notification

Before the product is made available in Great Britain, the Responsible Person must notify OPSS using the Submit Cosmetic Product Notifications (SCPN) service. Details are on the GOV.UK SCPN guidance page.

Products containing nanomaterials need extra information, and some need a separate nanomaterial notification. Ask your factory directly whether any ingredient is in nano form, because the label must also show "(nano)" after those ingredients.

8. Labelling rules

Under the GB cosmetics guidance, the container and any outer packaging must be easy to read and show:

Very small products under 5 g or 5 ml, such as free samples, may not need the date or the weight. Label and marketing claims must not suggest the product does things it does not, so keep words like "anti-ageing" or "clinically proven" for claims you can back up with evidence in the PIF.

9. Testing: stability, microbiology and more

Your safety assessor will tell you exactly which tests they need. For most leave-on skincare, expect to be asked for some or all of these:

• Stability testing: how the product holds up over time and temperature, in its final packaging. This supports your use-by date or period after opening.
• Compatibility testing: whether the formula reacts with the jar, pump or tube.
• Microbiological testing: that the product is clean when made.
• Preservative efficacy (challenge) testing: that the preservative system keeps the product safe once opened.
• Claims testing: only if you make claims such as "hydrates for 24 hours".

Many Chinese factories can arrange stability and microbiological tests, but check the lab and method are acceptable to your assessor before testing starts. Paying twice for tests is a common and avoidable cost.

10. Example landed cost in GBP

Import VAT is normally charged at import on top of duty and is usually recoverable if you are VAT registered. In this example, switching to Chinese glass jars could add a large anti-dumping duty on the container, which is why the packaging decision matters so much. Many skincare preparations under commodity code 3304 99 00 00 showed a 0% third-country duty when this guide was written, but always confirm your own code on the UK Trade Tariff.

11. A realistic launch timeline

1. Brief and factory shortlist: product list, claims, target price, packaging style and a verified shortlist of factories.
2. Samples: one to three rounds of formula and packaging samples. Lock the final version in writing.
3. Compliance file: collect formula, safety data and test reports, appoint your Responsible Person and safety assessor, and complete testing.
4. CPSR and artwork: the assessor signs off the safety report, and you finalise labels using their warnings.
5. Bulk production and QC: production, an inspection before shipment, then freight to the UK.
6. SCPN notification: notify OPSS before the product goes on sale.
7. Launch: keep your PIF up to date and record any reactions customers report.

For most first ranges, allow several months from brief to launch. Testing and the CPSR often take longer than production, so start the compliance file as soon as the formula is fixed.

12. How Epic Sourcing helps

Epic Sourcing finds, vets and manages the factory side of your beauty range from our teams in China and Vietnam. That includes factory checks, sample rounds, packaging, collecting the documents your safety assessor needs, production follow-up, inspections and shipping to the UK.

• Supplier Vetting: find and verify the right cosmetics factory.
• Sample Development: manage formula and packaging samples until you are happy.
• Private Label: our end-to-end package, from sourcing through production, quality control and shipping. See the Private Label package (from £3,299).

We can also run a stand-alone factory audit or pre-shipment inspection (Factory Audits & QC, £449 per report). Current prices for every package are on our pricing page. For product ideas, see our post on white label beauty products from China.

13. Frequently asked questions