UK Import Requirements Overview for Japan-Origin Products

UK cosmetics: SCPN and the UK Responsible Person

The UK Cosmetic Products Regulation is the EU CPR retained in UK law after Brexit. The structure mirrors the EU regime but uses UK-specific infrastructure:

• SCPN replaces CPNP for GB. The Submit Cosmetic Product Notification (SCPN) portal is the UK notification system. Products placed on the GB market must have a UK SCPN notification by the UK Responsible Person. Cosmetics for the Northern Ireland market continue to use CPNP under the EU CPR.
• The UK Responsible Person must be UK-established.A foreign brand owner cannot itself be the UK RP. Foreign brands appoint either a UK distributor with RP capability or a specialist UK RP service provider. The UK RP holds the Product Information File (PIF) and is the point of contact for OPSS.
• Bilateral RP arrangements with the EU are limited.A single EU/UK Responsible Person is no longer recognised across both regimes. Brands selling into both EU and UK typically need two separate RPs, one in the EU and one in the UK, with mirrored PIFs.

UK food labelling and supplements

The retained Food Information for Consumers Regulation is the framework for food labelling in Great Britain. Practical points for Japan-origin food and supplements:

• Mandatory particulars largely mirror the EU.Name of the food, ingredient list, allergen highlighting, quantity, date marking, storage instructions, name and address of the FBO responsible for the food information.
• FBO address must be UK-based for GB sales.The food business operator named on the label must have a UK address (or, before late 2023, an EU/EEA/UK address; the UK-only requirement was phased in). The Japanese manufacturer cannot be the FBO of record for the GB-side legal responsibility.
• Country of origin labelling.Mandatory where omitting it would mislead the consumer. "Made in Japan" or "Product of Japan" is the standard form.
• Supplements. Retained Directive 2002/46/EC plus UK national rules; the Food Supplements (England) Regulations 2003 and equivalents in Wales, Scotland, and Northern Ireland. Maximum permitted levels for some vitamins and minerals are advised by the Department of Health.
• Health and nutrition claims. Retained Regulation (EC) 1924/2006. Authorised health claims under the UK Register of Health Claims; the register draws from the EU register but is maintained separately post-Brexit.

UK novel food

The UK retained the EU novel food framework. Ingredients with no significant pre-1997 consumption history in the EU/UK require authorisation before being placed on the UK market. The FSA and FSS apply the framework in their respective territories.

• Full UK novel food authorisation. Application to the FSA / FSS with safety dossier. Timelines comparable to EU procedures (18–36 months) but with separate UK risk assessment.
• Traditional food from a third country.Simplified notification route comparable to the EU equivalent.
• EU pre-authorisations.Ingredients authorised under the EU regime before the UK's end-of-transition (end-2020) are recognised. New EU authorisations after that date are not automatic in the UK; a separate UK authorisation is required.

Customs: GB and Northern Ireland

• Great Britain (England, Wales, Scotland).Direct imports use the UK Customs Tariff and are filed to HMRC. UK EORI number required.
• Northern Ireland. Goods entering Northern Ireland from Great Britain go through the Internal Market Movement system under the Windsor Framework. Goods entering Northern Ireland from outside the UK or EU (i.e., direct from Japan) follow EU customs rules.
• UK–Japan Comprehensive Economic Partnership Agreement (CEPA). Preferential tariff treatment for most Japan-origin goods. Origin self-declaration available for consignments above and below the de minimis threshold; REX-equivalent registration not used (importer-knowledge or exporter declaration suffice).
• Import VAT. Postponed VAT accounting is available to UK VAT-registered importers, deferring the cash payment of import VAT to the next VAT return.

Practical sequencing for Japan-origin UK launch

1. Confirm novel food status of any non-standard Japanese ingredients.
2. Appoint a UK Responsible Person (cosmetics) or confirm the UK FBO of record (food, supplements). The UK FBO address goes on the product label.
3. Apply for CEPA preferential origin documentation on the Japanese side.
4. Submit SCPN notification (cosmetics) or finalise UK-compliant label artwork (food) in parallel with first production.
5. File the customs declaration in the UK Customs Tariff system; pay import VAT (postponed or direct) and any duty.
6. For dual-market launches into both UK and EU, mirror the PIF across the UK RP and the EU RP, and keep both notifications current.