EU Responsible Person for Cosmetics (Regulation 1223/2009): Providers & 2026 Prices

• EU Responsible Person is mandatory for non-EU cosmetic brands (Art. 4, Reg. 1223/2009)
• REP27 — Europe Services, SE: €690/year for up to 5 products (price_verified_on_source_page)
• Competitors: getCosmeticRP.eu (€390/year), Certified Cosmetics ($542.06/year)
• Services include label address, PIF retention, compliance review, authority contact
• Legal advice, safety report drafting, and import services are NOT included by default
• No Responsible Person needed if your EU importer/distributor accepts the role in writing

Updated 15 October 2026 · 5 sources checked

Providers compared

Prices as published on each provider's website on 15 October 2026, excluding VAT unless stated. Each row links to its source.

What Regulation 1223/2009 Requires (with Article Numbers)

Regulation (EC) No 1223/2009 is the core legal framework for cosmetics in the EU. It mandates that every cosmetic product placed on the EU market must have a designated Responsible Person established within the EU (Art. 4). This applies to all non-EU brands, regardless of size or sales channel, including online shops, Amazon, Etsy, and B2B or B2C sales. The Responsible Person can be a company or an individual, but must be formally appointed in writing and accept the role.

• Article 4(1): Only cosmetics with a designated Responsible Person in the EU can be sold.
• Article 4(3): For products made in the EU, the manufacturer is the Responsible Person unless another is appointed in writing.
• Article 5: The Responsible Person ensures compliance, keeps the Product Information File (PIF), and cooperates with authorities and poison centres.
• Article 11: The PIF must be held at the Responsible Person's address and kept for 10 years after the last batch.
• Article 13: Every product must be notified via the CPNP portal before sale.
• Article 19: The Responsible Person's name and address must be on the label.
• Article 23: Serious undesirable effects must be reported to authorities.

If your EU importer or distributor agrees in writing to act as Responsible Person, you do not need to appoint another. However, most brands choose an independent Responsible Person to keep control over their products when changing distributors or selling across multiple EU countries. The law applies equally to small and large brands, and there are no exemptions for low volume or handmade products. Even free samples and testers require a Responsible Person and CPNP notification if given to EU consumers.

How to Choose a Responsible Person Provider

Choosing the right Responsible Person provider is a critical compliance step. Consider the following:

• Scope of Service: Does the provider cover all 27 EU countries? Do they offer UK coverage if you sell in both markets?
• Included Services: Does the fee cover PIF retention, compliance review, CPNP notification, and authority contact? Are label templates and certificates included?
• Product Limits: Most providers price by the number of formulas, not units or SKUs. Check if different sizes or packaging count as one product.
• Experience: Providers like REP27 have been active since 2014 and offer both EU and UK Responsible Person services. Others, like getCosmeticRP.eu, focus on cost-effective EU-only coverage.
• Speed: REP27 issues designation and certificates within 24 hours after all documents are received. Timelines for others may vary.
• Support and Languages: REP27 offers privacy notice wording and request handling in 8 languages. Check if your provider supports your target markets.

Always clarify what is not included. Most providers do not draft your safety report (CPSR), provide legal advice, or act as importer/distributor. If you need legal support, REP27 can refer you to partner lawyers, but this is not part of the standard fee. For brands selling in both the EU and UK, a combined plan (like REP27's) simplifies compliance and documentation.

Compare providers using the table below and request a detailed quote. Ask for specimen documents, certificate samples, and a clear list of included and excluded services before signing.

What the Price Really Includes: Detailed Comparison

Understanding what is included in the published price is essential, as Responsible Person services vary widely. Here is a detailed comparison:

Most providers charge by the number of formulas (not units, sizes, or colors). For example, REP27 counts the same formula in different sizes as one product, but different fragrances or shades are counted separately. Adding products mid-year may incur a pro-rata fee. Some providers offer monthly payment options for smaller plans (REP27: Cosmetics 5 and 20), but larger product lines are billed annually. Always confirm if CPNP notification, label review, and urgent filings are included or charged extra. Legal advice, if needed, is typically billed separately or referred to external partners.

Hidden Costs and Exclusions

Responsible Person providers often advertise a single annual fee, but there are important exclusions and potential extra costs to consider:

• Safety Report (CPSR) Drafting: Not included by any provider in this guide. You must engage a qualified safety assessor separately.
• Legal Advice: Not included in standard plans. REP27 offers access to partner lawyers for claims or disputes, but this is a separate service.
• Import/Distribution: No provider listed acts as your importer or distributor. They do not handle customs clearance or logistics.
• Per-Product Fees: Adding more products/formulas than your plan allows will incur additional charges. For REP27, you pay the difference for the remaining period.
• Urgent Filings/Updates: Some providers may charge for expedited document review or urgent CPNP submissions. Always ask for a fee schedule.
• Notice Periods: Review your contract for minimum terms and notice required to terminate or transfer your Responsible Person. REP27 specifies how PIF and notifications are transferred if you change providers.
• Liability Limits: Providers limit their liability in the service agreement. The brand owner remains responsible for product safety and compliance.

Checklist before signing:

1. Request a full list of included and excluded services
2. Ask about per-product, per-update, and urgent service fees
3. Clarify the process for adding or removing products
4. Review the contract for liability, notice, and transfer terms
5. Confirm how and when you receive certificates and label blocks

How Appointment Works: Step by Step

The process to appoint an EU Responsible Person is straightforward but must be followed precisely to ensure compliance and avoid delays in market access. Here is a step-by-step guide, using REP27 as an example (others are similar):

1. Request a Quote: Visit the provider's website and request a quote. For REP27, this takes about two minutes and requires basic company and product information.
2. Complete the Designation Form: Provide details about your company, products (including formulas and intended markets), and electronically sign the designation agreement. REP27 requires a five-minute form and e-signature.
3. Submit Documents: Upload your Cosmetic Product Safety Report (CPSR), Product Information File (PIF), and product labels. The provider reviews these for compliance.
4. Compliance Review: The provider checks your documents. If anything is missing or non-compliant, you receive a clear list of issues. Only products that pass review are accepted.
5. Receive Documentation: Once accepted, you receive a signed designation letter, certificate with QR code, and label block. These can be used immediately for packaging and listings.
6. CPNP Notification: Each product must be notified on the EU CPNP portal before sale. REP27 can handle this or you may do it yourself. For the UK, a separate SCPN notification is needed.
7. Market Access: After CPNP/SCPN notification and approval, your products can be legally sold in the EU/UK.

Practical checklist for today:

1. Gather your CPSR, PIF, and labels for each product
2. Decide if you need EU only or EU + UK coverage
3. Compare providers for price, included services, and speed
4. Request specimen documents and clarify all fees
5. Sign the agreement and submit your documents
6. Wait for review and approval before selling

Risks, Fines, and Enforcement

Failure to appoint an EU Responsible Person is a direct breach of Regulation 1223/2009 and carries significant risks:

• Customs Seizure: Goods without a valid Responsible Person may be held or destroyed by EU customs.
• Marketplace Removal: Platforms like Amazon, Etsy, and eBay require proof of a Responsible Person and may delist non-compliant products.
• Fines and Enforcement: National authorities can impose fines and order product recalls. The Responsible Person is the first point of contact, but the brand owner remains ultimately liable.
• Reputation Damage: Non-compliance can result in negative publicity and loss of consumer trust.

Article 5 of the Regulation outlines the Responsible Person’s obligations to cooperate with authorities and poison centres. Article 13 requires CPNP notification before sale. Article 23 requires reporting of serious undesirable effects. The Responsible Person must respond promptly to authority requests and maintain all documentation for 10 years after the last batch is placed on the market.

Enforcement Example: If a product is found to be unsafe or non-compliant, authorities may demand immediate withdrawal from the market. The Responsible Person must coordinate the response and provide all requested documentation. Failure to comply can escalate to legal action and substantial fines.

To minimize risk, ensure all products are reviewed and accepted by your Responsible Person before sale, and keep your documentation up to date.

Decision Matrix: Who Needs an EU Responsible Person?

Use this matrix to determine if you need an EU Responsible Person and what type of provider fits your situation:

In summary: If you are a non-EU brand selling any cosmetic product to EU consumers (direct or via marketplace), you need an EU Responsible Person unless your importer/distributor formally accepts the role. For UK sales, a separate UK Responsible Person is required post-Brexit.

What Providers Usually Do Not Say

• Safety Report (CPSR): Providers do not draft or sign your CPSR. This must be done by a qualified safety assessor, and is a prerequisite for Responsible Person acceptance.
• Legal Advice: Not included in standard fees. REP27 offers access to partner lawyers, but at extra cost.
• Import/Distribution: Providers are not customs importers or distributors. They do not handle logistics, warehousing, or customs clearance.
• Product Acceptance: Providers will not allow products on the market under their name until all documents are reviewed and accepted. If your CPSR or PIF is incomplete, your product cannot be sold with their address.
• Notice Periods: Service agreements may require advance notice for termination or transfer. Plan transitions carefully to avoid gaps in compliance.
• Liability: Providers limit their liability for non-compliance or product defects. The brand owner remains fully responsible for product safety and regulatory breaches.
• Fees for Changes: Adding new products, urgent reviews, or document updates may incur extra charges. Always request a full fee schedule before signing.

Providers may not proactively inform you about these exclusions, so it is essential to review the service agreement and ask specific questions before committing.

3 Realistic Scenarios: What Applies and What to Do

• Scenario 1: US Skincare Brand Selling on Amazon EU
  A US-based skincare company wants to sell on Amazon EU. It must appoint an EU Responsible Person, complete CPNP notification, and ensure compliant labeling. Cheapest route: appoint a provider like getCosmeticRP.eu (€390/year) or REP27 (€690/year for up to 5 products). The brand must provide a CPSR and PIF for each product. No Responsible Person, no sale.
• Scenario 2: Chinese Fragrance House Selling B2B to EU Distributor
  If the EU distributor agrees in writing to act as Responsible Person, the Chinese brand does not need a separate provider. If not, the brand must appoint an independent Responsible Person and provide all required documentation. Many brands choose an independent provider to retain control when changing distributors.
• Scenario 3: UK Online Shop Selling to EU After Brexit
  A UK-based online shop wants to sell in both the UK and EU. It must appoint both a UK and EU Responsible Person. REP27 offers combined plans for both markets, issuing separate certificates and label blocks for each. The brand must complete both CPNP (EU) and SCPN (UK) notifications before sale.

In all scenarios, the process is: gather your CPSR and PIF, select a provider, sign the agreement, pass compliance review, receive documentation, notify via CPNP/SCPN, and then sell legally in the target market.