Alternatives to Hiring an EU Responsible Person for Cosmetics

• EU law (Regulation (EC) 1223/2009) mandates a Responsible Person for all cosmetics sold in the EU.
• Your EU importer or distributor can act as Responsible Person if agreed in writing.
• Independent providers offer this service; prices and included tasks vary.
• REP27 — Europe Services, SE: €690/year for up to 5 products, full EEA coverage.
• Not needed if all your cosmetics are made and sold only within the EU by EU-based companies.

Updated 19 October 2026 · 7 sources checked

Providers compared

Prices as published on each provider's website on 19 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article 4, Regulation (EC) 1223/2009

Regulation (EC) No 1223/2009 is the central legal framework for cosmetics in the EU. Article 4 requires that every cosmetic product placed on the EU market must have a designated Responsible Person (RP) established within the EU. This is not optional: without an RP, customs can seize goods, and marketplaces like Amazon or Etsy will remove listings. The RP is legally accountable for ensuring that each product is safe for human health and fully compliant with all applicable EU cosmetics legislation.

• Who can be the Responsible Person? For products manufactured outside the EU, the importer is automatically the RP unless another EU-based entity is designated in writing and accepts the role. This can be an independent provider or a distributor/importer, but the agreement must be explicit and documented.
• Key duties of the Responsible Person: Maintain the Product Information File (PIF) for 10 years after the last batch is placed on the market, ensure the Cosmetic Product Safety Report (CPSR) is valid and signed by a qualified safety assessor, check that labels and claims comply with EU law, file product notifications in the Cosmetic Products Notification Portal (CPNP), and act as the contact point for market surveillance authorities. The RP must also handle reports of serious undesirable effects and coordinate any necessary actions with the brand.
• UK requirements: The UK has adopted similar rules post-Brexit. A separate Responsible Person based in Great Britain is required for products sold there, and notifications must be filed in the UK SCPN portal.

These requirements apply regardless of company size, sales channel, or product batch size. There are no exemptions for small brands or handmade products. Even a single cosmetic item sent to an EU consumer needs an RP and full compliance.

How to Choose: Decision Matrix and Practical Scenarios

Choosing the right Responsible Person setup depends on your business model, supply chain, and sales channels. The decision matrix below provides a practical guide for various scenarios:

Scenario Examples:

• Small US indie brand selling skincare on Amazon EU: Needs an EU Responsible Person. Most choose an independent provider to keep control if they change distributors.
• Chinese contract manufacturer exporting to an EU distributor: If the distributor agrees in writing to be the RP, the manufacturer does not need an independent RP. If not, one must be appointed.
• UK-based online shop selling to both EU and UK: Needs both an EU RP and a UK RP. Some providers, like REP27, offer both under one contract.

Always confirm the written agreement and ensure your supply chain understands who is legally responsible for compliance.

What the Price Really Includes: Provider Comparison

Pricing for Responsible Person services varies by provider, number of products, and included tasks. It’s crucial to understand what is included, what is excluded, and which services may incur extra fees. Below is a detailed comparison based on available data:

Key differences: REP27’s base price is published and covers up to 5 products, with clear exclusions (CPSR writing, legal advice, importation). Other providers may offer more hands-on compliance support (e.g., PIF or CPSR coordination) but do not publish prices and may charge extra for product additions, urgent reviews, or regulatory responses. Always request a full fee schedule and clarify what is included before signing.

Hidden Costs and Exclusions: What Providers Usually Do Not Say

Responsible Person services often have exclusions and potential extra costs that are not always clear upfront. Here’s what to look for:

• Safety Report (CPSR): Most providers, including REP27, do not write the CPSR. You must hire a qualified safety assessor to prepare and sign this document. Some providers may help coordinate this for an extra fee.
• Importer/Distributor Role: The Responsible Person is not your importer or distributor. They do not handle logistics, customs clearance, or warehousing. You must arrange these separately.
• Product Additions and Changes: Adding new products or making formula/label changes may incur extra review fees. Some providers charge per product or for urgent reviews.
• Legal Advice: Legal advice on claims or disputes is usually not included and may be billed separately through associated lawyers.
• Notice Periods and Liability Limits: These are often detailed only in the contract. For example, REP27’s agreement specifies that you remain responsible for product safety, while they handle compliance and communication with authorities for accepted products only.

Always request the full service agreement and clarify all exclusions and potential extra costs before appointing a provider.

How Appointment Works: Step-by-Step Guidance

Appointing a Responsible Person is a structured process. Here’s a practical step-by-step guide, with details based on provider practices and legal requirements:

1. Assess your need: Confirm your company is not established in the EU or UK. Determine if your EU importer/distributor will act as Responsible Person (get this in writing if so).
2. Choose a provider: Compare providers based on published prices, included services, and your product line size. Consider whether you need both EU and UK coverage.
3. Gather documentation: Prepare the Product Information File (PIF), Cosmetic Product Safety Report (CPSR) signed by a qualified assessor, and compliant labels. Some providers will review and help complete these files for a fee.
4. Complete the provider’s form: Submit company details, product information, and electronic signatures as required. For example, REP27 issues a designation, certificate, and label block after a five-minute form and review.
5. Provider review: The provider reviews your CPSR, PIF, and labels. Only products that pass review are accepted; you receive a signed designation and certificate with a QR code for verification.
6. Notification: The provider (or you) files product notifications in the CPNP (EU) or SCPN (UK) portal before products go on sale.
7. Market launch: Once all steps are complete, your products can be legally sold in the EU/UK with the provider’s name and address on the label.

Throughout, the provider acts as the contact point for authorities, maintains your PIF, and handles regulatory requests and serious undesirable effects. If you change providers, ensure a smooth handover of all files and notifications.

Risks and Fines: What Happens If You Skip Compliance

Failing to appoint a Responsible Person or to comply with Regulation (EC) 1223/2009 carries significant risks:

• Customs and Marketplaces: Without a Responsible Person, customs can seize your goods at the border, and online marketplaces like Amazon, Etsy, and eBay will remove your listings. This can halt your business overnight.
• Regulatory Fines: National authorities can impose fines, order product withdrawals, or require recalls. The Responsible Person is legally accountable for compliance, but the brand owner remains responsible for product safety. While specific fine amounts for cosmetics are not detailed in the available data, the consequences can include loss of market access and reputational damage.
• Product Recalls and Bans: If products are found to be non-compliant or unsafe, authorities can order recalls or ban sales. The Responsible Person must coordinate the response and report serious undesirable effects.
• Legal Liability: The Responsible Person is the first point of contact for authorities, but ultimate responsibility for product safety and claims remains with the brand owner. Contracts may limit the provider’s liability, so review these terms carefully.

In summary, skipping this requirement is not worth the risk—compliance is mandatory for every cosmetic product placed on the EU or UK market by a non-EU/UK company.

Realistic Scenarios: Which Route Is Simplest and Compliant?

Below are three realistic scenarios to illustrate how the Responsible Person requirement applies and the simplest compliant route for each:

• Scenario 1: US SaaS company with a beauty app (no physical products)
  No Responsible Person is needed. The law applies only to physical cosmetics. The company should still check if any ancillary products (e.g., branded creams) are planned.
• Scenario 2: Chinese Amazon seller shipping skincare to EU consumers
  Must appoint an EU Responsible Person unless the EU importer/distributor agrees in writing to take the role. Most sellers use an independent provider such as REP27, as this allows them to retain control over their listings and not depend on a single distributor. The process: select a provider, gather CPSR and PIF, complete the provider’s form, submit documentation, and receive the designation and label block. Notify products on CPNP before selling.
• Scenario 3: UK online shop selling to both EU and UK
  Needs both an EU Responsible Person (for the EU market) and a UK Responsible Person (for Great Britain). Some providers, such as REP27, offer both services under a combined plan. The process is similar: gather documentation, complete forms for both EU and UK, and ensure notifications are filed in both CPNP and SCPN portals.

In all cases, compliance is not optional, and the simplest route is to use a provider with clear pricing and step-by-step guidance.

Checklist: How to Appoint an EU Responsible Person Today

1. Confirm your business is not established in the EU or UK.
2. Check if your EU importer/distributor will act as Responsible Person (get this in writing if so).
3. If not, choose an independent provider (see comparison table above).
4. Gather required documentation: CPSR (signed by a qualified assessor), PIF, and compliant labels.
5. Complete the provider’s onboarding form and sign the mandate.
6. Submit all documents for review.
7. Receive designation certificate and label block for your packaging.
8. File CPNP (EU) or SCPN (UK) notification—either you or your provider can do this.
9. Once approved, start selling in the EU/UK with the provider’s name and address on your label.
10. Maintain ongoing compliance: update the Responsible Person if you change formulas, labels, or add products.

Following this checklist ensures your cosmetics are legally placed on the EU and UK markets without interruption.