How Much Does It Cost to Hire an EU Responsible Person for Cosmetics?

• EU Responsible Person is mandatory for non-EU brands selling cosmetics in the EU (Reg. 1223/2009, Art. 4).
• REP27 — Europe Services, SE: from €690/year for up to 5 products (price_verified_on_source_page).
• Competitor prices (2026): €249–$542/year, or monthly/one-off fees.
• Services may or may not include product notifications, document review, or extra products.
• Not needed if your EU importer/distributor acts as Responsible Person in writing.
• Fines for non-compliance can block sales and trigger penalties (Art. 23).

Updated 17 October 2026 · 5 sources checked

Providers compared

Prices as published on each provider's website on 17 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires (with Article Numbers)

Cosmetic products sold in the EU are governed by Regulation (EC) No 1223/2009. The regulation is strict and applies to every cosmetic placed on the EU market, regardless of where the brand is based. The key requirements are:

• Article 4: Every cosmetic product must have a Responsible Person established in the EU. This can be a legal or natural person. If the product is imported, the importer is the Responsible Person unless another party is designated in writing and accepts the role.
• Article 10: The Responsible Person must ensure that each cosmetic has undergone a safety assessment and a Cosmetic Product Safety Report (CPSR) is prepared by a qualified safety assessor.
• Article 11: A Product Information File (PIF) must be kept at the address of the Responsible Person for 10 years after the last batch of the product is placed on the market.
• Article 13: Cosmetic labels must display the Responsible Person’s name and address, the country of origin (if imported), and a complete ingredient list.
• Article 16: Each product must be notified via the Cosmetic Products Notification Portal (CPNP) before being sold in the EU.
• Article 23: Member States must enforce compliance and can impose penalties and remove non-compliant products from the market.

These rules apply to all sales channels, including online shops, Amazon, Etsy, and other marketplaces. There are no exemptions for small, handmade, or low-volume brands. The Responsible Person is the first point of contact for market surveillance authorities and is responsible for vigilance reporting (serious undesirable effects).

How to Choose a Responsible Person Provider

Choosing the right Responsible Person provider is essential for legal compliance and smooth market access. The main factors to consider are:

• Price structure: Some providers charge per product, per family, or per notification. Others offer bundled plans for multiple products. For example, REP27 — Europe Services, SE charges €690/year for up to 5 products, while Grüner Baum GmbH charges €249/year for one low-risk product family.
• What’s included: Not all providers offer the same services. Some only provide the legal designation, while others include document review, CPNP notification, label templates, and vigilance reporting. For instance, REP27 includes product review, notification support, and label block, while Certified Cosmetics and Eldris do not specify these extras.
• Extra fees: Always clarify if there are additional charges for extra products, urgent reviews, document updates, or legal advice. Some providers may charge for each new product or for handling notifications.
• Jurisdiction: The provider must be established in the EU (and in the UK if you sell there). REP27 offers both EU and UK coverage in one package; others may not.
• Sales channel experience: If you sell on Amazon, Etsy, or other marketplaces, confirm the provider’s experience with those platforms. Some, like Eldris, highlight Amazon compliance support.

Before signing, ask for a detailed service agreement and clarify all inclusions and exclusions. If you need both EU and UK coverage, confirm if the provider can supply both and if there is a combined rate.

What the Price Really Includes

Pricing for Responsible Person services varies widely, and what’s included can differ significantly between providers. Here’s what to look for:

• Number of products/formulas covered: Some plans cover a set number of products (e.g., REP27 covers up to 5 for €690/year), while others charge per product family (Grüner Baum GmbH) or per notification.
• CPNP notification: Some providers include filing product notifications with the EU portal (CPNP) as part of their service; others may charge extra or expect you to file yourself. REP27 offers to notify each product or allows you to do it yourself.
• PIF holding and updates: The Responsible Person must keep the Product Information File (PIF) accessible for 10 years after the last batch. Confirm if updates and document storage are included in the price.
• Label review and templates: Providers like REP27 review your safety report, label, and PIF before accepting a product and supply a label block for immediate printing. This helps avoid costly relabeling or customs issues.
• Authority liaison and vigilance reporting: The Responsible Person must respond to requests from authorities and report serious undesirable effects. Some providers guarantee same-day forwarding of authority requests (REP27), while others do not specify response times.
• UK coverage: If you sell in the UK, you need a separate UK Responsible Person. REP27 offers a combined EU+UK plan; check if other providers do as well.

Always ask for a breakdown of what is included in the published price and request a sample of the documents and certificates you will receive. This is especially important for Amazon and other marketplaces that require verifiable documentation.

Hidden Costs and Exclusions

Many brands are surprised by extra costs or limitations that are not obvious at first glance. Here’s what to watch for:

• Additional products: Most base plans cover a limited number of products or formulas. Adding more usually incurs extra fees. With REP27, you pay for additional products above the plan limit; Grüner Baum GmbH charges per product family.
• Document updates and urgent reviews: Some providers charge for updating the PIF, label, or safety report, or for expedited document review. Always clarify turnaround times and costs for urgent requests.
• Legal advice: Legal advice on claims, disputes, or regulatory questions is rarely included. REP27 offers access to associated lawyers for an extra fee; other providers may not offer this at all.
• UK Responsible Person: Post-Brexit, a separate UK Responsible Person is required. Some providers bundle this at a combined rate (REP27); others treat it as a separate service.
• Termination and transfer: If you switch providers, you may need to pay for document transfer, update notifications, and relabel products. Notice periods and liability limits may apply; always check the service agreement.

What’s usually not included:

• Writing your CPSR (safety report) — this must be done by a qualified safety assessor.
• Importer or distributor services — the Responsible Person is not your importer, does not handle customs, and does not take ownership of goods.
• Logistics or warehousing — not included in Responsible Person services.

Ask for a full list of exclusions and request written confirmation of all fees before signing.

How Appointment Works: Step by Step

The process of appointing an EU Responsible Person is structured and can be completed quickly if you have your documents ready. Here’s how it works in practice:

1. Choose a provider and plan: Select a provider based on your product count, markets (EU, UK, or both), and service inclusions. Compare published prices and clarify what is covered.
2. Prepare your documents: Gather your Cosmetic Product Safety Report (CPSR) for each product, Product Information File (PIF), and draft labels. The CPSR must be signed by a qualified safety assessor; the Responsible Person will not write it for you.
3. Submit company and product details: Complete the provider’s online form (e.g., REP27’s five-minute form), including company information, product details, and electronic signature.
4. Provider review: The provider reviews your CPSR, PIF, and labels to ensure compliance. Any missing or non-compliant elements are listed product by product. Only products that pass review are accepted.
5. Sign the designation and pay: Sign the electronic designation agreement and pay the annual fee. The provider then issues the official designation letter, certificate with QR code, and label block for immediate printing.
6. Product notification: Each product must be notified via the CPNP (EU) and/or SCPN (UK) portal before sale. Some providers handle this for you; others expect you to file notifications yourself.
7. Start selling: Once the product is accepted and notified, you can sell it in the EU/UK. The Responsible Person holds your PIF and responds to authority requests as required.

Typical timeline: REP27 can issue the designation within 24 hours after payment and form submission, but product-specific approval depends on the completeness of your documents.

Risks and Fines for Non-Compliance

Failing to appoint an EU Responsible Person or not meeting the requirements of Regulation (EC) No 1223/2009 carries significant risks:

• Product removal: Marketplaces (Amazon, Etsy, etc.) and customs authorities can remove your products from sale or block imports if you cannot provide a valid Responsible Person certificate and documentation.
• Fines and penalties: Article 23 requires Member States to enforce compliance, including penalties for non-compliance. While specific fines are not listed in the regulation, authorities can impose significant penalties and block further sales.
• Reputation damage: Non-compliance can harm your brand’s reputation, especially if products are recalled or blocked at the border.
• Loss of market access: Without a Responsible Person, you cannot legally sell cosmetics in the EU or UK. Even free samples or trial sizes count as “placing on the market.”

Compliance checklist:

1. Confirm if your importer/distributor will act as Responsible Person in writing. If not, appoint an independent provider.
2. Prepare your CPSR and PIF for each product.
3. Appoint and pay your Responsible Person.
4. Update labels with the Responsible Person’s name and address.
5. File notifications (CPNP/SCPN) before sale.
6. Keep all documentation updated and accessible for 10 years after the last batch.

Failure at any step can result in enforcement action. There are no exemptions for small brands or low sales volume.

Decision Matrix: Who Needs an EU Responsible Person?

This matrix covers the most common cases. If in doubt, consult the text of Regulation (EC) No 1223/2009 or seek legal advice (not included in most Responsible Person services).

What Providers Usually Do Not Say

• CPSR not included: The Responsible Person does not write your Cosmetic Product Safety Report (CPSR). You must hire a qualified safety assessor for this critical document.
• No importer or distributor services: Responsible Person providers do not act as your importer, do not handle customs, and do not take ownership of goods. This is a separate legal and logistical role.
• Legal advice is extra: Most providers do not include legal advice on marketing claims, disputes, or regulatory interpretation. REP27 offers access to associated lawyers for an extra fee.
• Notice periods and liability limits: If you terminate the service, there may be notice periods and liability limits. Products cannot be sold with the old Responsible Person’s name after termination.
• Per-product or per-notification charges: Some providers charge for each product, formula, or notification. Always clarify how your products are counted and what happens if you add new ones mid-year.
• Document transfer on switch: If you change providers, you must transfer your PIFs and update all notifications and labels. This can be time-consuming and may incur extra fees.

Always request the full service agreement and clarify all terms before appointing a Responsible Person.

Realistic Scenarios

• US SaaS company selling cosmetic devices to EU consumers: The company must appoint an EU Responsible Person for each cosmetic product, prepare a CPSR and PIF, and update labels with the Responsible Person’s details. REP27’s plan covers up to 5 products for €690/year. The company must also file CPNP notifications before any sales.
• Chinese Amazon seller launching skincare in Germany: The seller needs an EU Responsible Person, must prepare safety reports and PIFs, and update packaging. REP27 or a similar provider can cover all 27 EU countries with one appointment. The seller must notify each product on CPNP and cannot sell until approval is complete.
• UK online shop selling to EU post-Brexit: The shop must appoint both an EU and a UK Responsible Person, as each market requires a local contact. REP27 offers a combined EU+UK plan. The shop must prepare separate notifications for the EU (CPNP) and UK (SCPN) and keep documentation updated for both markets.

These scenarios show that the Responsible Person requirement applies regardless of company size or sales channel. The simplest compliant route is to appoint an independent provider, prepare all required documents, and follow the notification and labeling steps before selling.