Responsible Person
What is a Responsible Person (Cosmetics)?
A Responsible Person (Cosmetics) is a natural or legal person established within the European Union who is designated as legally accountable for the compliance of a cosmetic product placed on the EU market under Regulation (EC) No 1223/2009. Every cosmetic product placed on the EU market must have a named Responsible Person, and their name and address must appear on the product label.
Why It Matters
The Responsible Person is the cornerstone of the EU Cosmetics Regulation’s compliance framework. They are the single point of accountability for every cosmetic product placed on the EU market and are responsible for ensuring the product is safe, correctly labelled, notified through the CPNP, and supported by a complete Product Information File.
For non-EU manufacturers, appointing an EU-established Responsible Person is a mandatory legal requirement before any cosmetic product can be sold to EU consumers. Without one, the product cannot lawfully be placed on the EU market — whether through physical retail, a brand website, or third-party online marketplaces.
For cosmetic brands, contract manufacturers, and ecommerce sellers, understanding the Responsible Person role is essential for achieving and maintaining lawful access to the EU cosmetics market.
Key Requirements
Who Needs to Appoint a Responsible Person?
A Responsible Person must be designated for every cosmetic product placed on the EU market. This is required when:
- The manufacturer is established outside the EU, or
- An EU-established manufacturer places a product on the market under a third party’s name or trademark
This requirement applies under:
- Regulation (EC) No 1223/2009 — EU Cosmetics Regulation, Article 4
The Responsible Person must be established within the EU and must be identified on the product label by name and address.
Responsibilities of a Responsible Person (Cosmetics)
While obligations are set out in detail in the EU Cosmetics Regulation, responsibilities commonly include:
- Ensuring the cosmetic product has a completed Cosmetic Product Safety Report (CPSR) before it is placed on the market
- Maintaining a Product Information File (PIF) for the product and making it available to competent authorities upon request
- Notifying the product on the Cosmetic Products Notification Portal (CPNP) prior to placing it on the market
- Ensuring the product label meets all applicable requirements under the regulation
- Reporting serious undesirable effects to the relevant competent authority
- Cooperating with market surveillance authorities during inspections or investigations
- Ensuring the product does not contain any prohibited or restricted substances in violation of the regulation
Responsible Person vs. Manufacturer
These are distinct roles under the EU Cosmetics Regulation. The manufacturer produces the cosmetic product. The Responsible Person is the EU-established entity legally accountable for its compliance on the EU market. In some cases these may be the same entity — for example, where an EU-based manufacturer places products on the market under their own name. For non-EU manufacturers, a separate EU Responsible Person must always be appointed.
Need EU cosmetics compliance support?
Euverify provides Responsible Person services for cosmetic brands and manufacturers placing products on the EU market under the EU Cosmetics Regulation. Our team supports CPNP notification, product information file management, regulatory communication, and ongoing compliance management.
Related Terms
Further Reading
