Costs, Duties & Providers: EU Responsible Person for Cosmetics under Regulation 1223/2009

• Mandatory for all non-EU cosmetic brands selling in the EU
• Price from €690/year (REP27 — Europe Services, SE, up to 5 products)
• Services: address on label, PIF storage, authority contact
• Not included: safety report (CPSR) – must be commissioned separately
• Marketplaces like Amazon require an EU Responsible Person
• Importers or distributors can take this role if agreed in writing

Updated 26 October 2026 · 7 sources checked

Providers compared

Prices as published on each provider's website on 26 October 2026, excluding VAT unless stated. Each row links to its source.

What exactly does Regulation (EC) No. 1223/2009 require?

Regulation (EC) No. 1223/2009 has been the binding legal basis for all cosmetic products sold in the EU since 11 July 2013. According to Article 4, every cosmetic product placed on the EU market must have a responsible person established within the Union. This person is responsible for compliance with all requirements of the regulation – from product safety to labeling and authority contact.

• Product Information File (PIF): A PIF must be created for each product and kept at the responsible person's address for 10 years after the last placing on the market (Art. 11).
• Safety Assessment (CPSR): Each product requires a safety assessment by a qualified assessor (Art. 10). The responsible person reviews whether this is available but usually does not create it themselves.
• CPNP Notification: Before placing the product on the market, it must be notified in the Cosmetic Products Notification Portal (CPNP) (Art. 13).
• Label: The responsible person's address must appear on the packaging (Art. 19).
• Authority Contact and Vigilance: The responsible person is the contact point for authorities, must respond to inquiries, and report serious adverse effects (Art. 23).

The responsible person can be the manufacturer, importer, distributor, or a contracted third party but must be designated in writing. Without a responsible person, sales bans and penalties may apply. Products that do not comply with the regulation must not be placed on the EU market.

Important: Samples and testers are also considered placing on the market and require a responsible person and CPNP notification. The regulation applies equally to B2C and B2B products.

How to choose the right provider? Decision aids and matrix

The choice of the appropriate EU Responsible Person depends on several factors: number of products, speed to market, scope of services, marketplace requirements (Amazon, Etsy, eBay), and desired additional services. Providers differ in price structure, service scope, and additional offerings. Before choosing, check:

• Does the provider cover all 27 EU countries with one appointment?
• How quickly do you receive the required label data and certificate?
• Which services are included in the price (e.g., PIF storage, authority contact, label address, CPNP notification)?
• How are additional products charged?
• Are there hidden fees, minimum terms, or cancellation periods?
• Does the provider offer proofs like QR codes on certificates accepted by marketplaces?

Decision matrix:

Practically: Many brands choose an independent Responsible Person to remain flexible if they change importer or distributor. Marketplaces usually require proof (e.g., certificate with QR code), which not every provider can deliver immediately.

What is included in the price? – Detailed provider comparison

Providers’ services differ significantly. A close look at included and excluded services is crucial to avoid unpleasant surprises. Here is a comparison of the main providers:

Important: The creation of the safety report (CPSR) is almost never included and must be commissioned separately from a qualified safety assessor. CPNP notification is not always included or may incur additional costs. Check how many products are covered by the base price and how additional products are billed.

Hidden costs, exclusions, and typical contract details

Many providers exclude certain services or charge separately. Key points to watch out for:

• Safety report (CPSR): Almost never included in the price. Must be created separately by a qualified safety assessor. Providers like REP27 review the report but do not create it.
• Additional products: Base prices usually cover a certain number of products (e.g., 5 at REP27). Additional formulas or product variants incur extra fees. Pricing tiers and conditions are available on request.
• CPNP notification: Not always included. Some providers handle or support notification; others offer only consulting.
• Cancellation periods and transfer: When changing the Responsible Person, the PIF and CPNP notification must be transferred to the new person. Check contract terms for cancellation and data transfer.
• Liability: Responsibility relates to regulatory compliance, not product liability or ingredient-related damages. Liability is usually contractually limited.
• Importer/distributor: They can act as Responsible Person if agreed in writing. Many brands still choose an independent third party.

Practical tip: Get all services and exclusions confirmed in writing and ask specifically about extra fees for product changes, additional notifications, or special services.

How the ordering process works – Step-by-step & checklist

The appointment of an EU Responsible Person usually follows a clear process to ensure your product reaches the market quickly and legally:

1. Select provider: Compare prices and services, request an offer.
2. Provide information: Company and product data, if available safety report (CPSR), PIF, label draft.
3. Sign contract and pay: After signing and payment, you receive the address for the label and possibly a certificate with QR code.
4. Prepare label and documents: Print the Responsible Person’s address on the label, finalize PIF and CPSR.
5. Provider review: Provider reviews CPSR, PIF, and label. Missing documents are clearly identified.
6. CPNP notification: Product is registered in the CPNP portal (by yourself or provider).
7. Start selling: Once all documents are checked and notification completed, the product can be sold in the EU.

Checklist for today:

1. Do you have a written agreement with an EU importer as Responsible Person? If not, select a provider.
2. Is your safety report (CPSR) ready? If not, commission it.
3. Is the PIF complete and up to date?
4. Is the label with EU address prepared?
5. Is CPNP notification planned or already done?

With REP27, appointment and provision of label data happen immediately after payment and form submission. Products may only be sold after successful review and notification.

Risks, penalties and liability – What happens in case of violations?

Appointing a Responsible Person is not a formality but a key prerequisite for market access. Failure to appoint an EU Responsible Person or comply with Regulation (EC) No. 1223/2009 risks serious consequences:

• Sales ban: Products without a Responsible Person cannot be sold anywhere in the EU. Marketplaces like Amazon, Etsy, or eBay will promptly remove affected products.
• Penalties: According to Art. 23, national authorities can impose fines. Amounts vary by country and case.
• Liability: The Responsible Person is liable for regulatory compliance but not for product safety itself – this remains with the manufacturer or the CPSR signatory.
• Authority contact: The Responsible Person is the first contact for authorities and must respond to inquiries, recalls, or serious adverse effects.
• Loss of market access: Without valid appointment and complete documents, lengthy delays and financial damage may occur.

Practical tip: Regularly check that all documents are current and the Responsible Person remains reachable. When changing providers, ensure timely transfer of PIF and CPNP notification.

What providers often don’t say – Exclusive practical knowledge

• Safety report (CPSR): Creation is almost never included. Providers like REP27 review the report but assume no liability for its content.
• Additional fees: New products, product changes, or special services usually incur extra costs that are not always transparently disclosed.
• Cancellation periods: When changing Responsible Person, cancellation periods and PIF transfer must be observed.
• Importer/distributor: They can act as Responsible Person if agreed in writing, especially relevant for exclusive distribution models.
• Liability scope: Responsibility usually covers regulatory compliance only. Product liability or claims from faulty safety assessments are excluded.
• Marketplace requirements: Amazon and others often require immediately verifiable proof (e.g., QR code on certificate). Not all providers offer this.

Practical tip: Have all services, exclusions, and extra costs confirmed in writing. Ask specifically how many products are included in the base price and how additional products are charged.

Three typical scenarios – Who needs what and how to proceed?

• US startup (B2C, Amazon EU): A US company wants to sell perfumes on Amazon in the EU. Amazon requires an EU Responsible Person whose address appears on the label and is verifiable by certificate. Fastest solution: providers like REP27 who deliver label data and a verifiable certificate immediately after payment and form submission. CPNP notification can be done by the company or provider. The safety report (CPSR) must be commissioned separately.
• Chinese Amazon seller: A Chinese manufacturer sells cosmetic products to EU end customers. Without an EU Responsible Person, products are removed by Amazon. An independent Responsible Person like REP27 or Certified Cosmetics is required. The address must be on the label; PIF and CPSR must be available; CPNP notification must be done.
• UK online shop after Brexit: A UK online shop wants to continue selling to the EU. An EU Responsible Person is required for the EU market, and a separate UK Responsible Person for the UK. REP27 offers combined solutions for both markets. Labels must contain both addresses, and product notifications must be made in both portals (CPNP and SCPN).

Practical tip: Before market entry, check if your distribution model requires your own Responsible Person or if your importer/distributor assumes the role. For marketplace sales, an independent Responsible Person is usually mandatory.