How to Compare EU Responsible Person Providers for Cosmetics and Perfumes

• EU Responsible Person is mandatory for all cosmetics under Regulation (EC) 1223/2009, Article 4
• Compare by EU establishment, published price, included services, and speed of documentation
• REP27 covers all 27 EU countries and UK (optional), from €690/year for up to 5 products
• Providers may charge per product or for extra services—always verify details
• Not needed if your EU importer/distributor agrees in writing to act as Responsible Person

Updated 19 October 2026 · 4 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

Every cosmetic product placed on the EU market must have a designated Responsible Person (RP) established within the European Union, as set out in Article 4 of Regulation (EC) 1223/2009. This applies to all cosmetics and perfumes, regardless of where they are manufactured or sold, including online sales and sales through marketplaces like Amazon or Etsy. The RP is legally responsible for ensuring the product’s compliance with EU law, including:

• Ensuring the product has undergone a formal safety assessment (Article 10, CPSR)
• Maintaining the Product Information File (PIF) for at least 10 years after the last batch is placed on the market (Article 11)
• Ensuring the product is notified on the Cosmetic Products Notification Portal (CPNP) before sale (Article 13)
• Ensuring the label carries the correct information, including the RP’s name and address (Article 19)
• Reporting serious undesirable effects to authorities (Article 23)

The RP is the first point of contact for market surveillance authorities and must respond promptly to requests for information or documentation. Failure to appoint an RP can lead to products being blocked at customs, delisted from marketplaces, and fines or enforcement action by national authorities. The law applies equally to B2C and B2B sales if the product reaches EU consumers. There are no exemptions for small batches or online-only sales. If your EU importer or distributor agrees in writing to act as RP, you do not need an independent provider, but most brands prefer an independent RP to retain control over their products and compliance.

How to Choose a Responsible Person Provider

Choosing the right EU Responsible Person provider is critical for compliance and business continuity. Here’s what to look for:

• EU Establishment: The provider must be legally established in the EU. This is a legal requirement—non-EU entities cannot act as RP for EU sales.
• Coverage: Confirm that the provider covers all 27 EU countries (plus EEA states). Some only cover one country, which is insufficient for EU-wide sales.
• Published Price: Look for transparent, published pricing. Check if the price is per product/formula, per notification, or includes all products in your range.
• Included Services: Does the price include PIF holding, CPNP notification, label and CPSR review, and acting as authority contact? Is UK coverage available as an add-on?
• Process and Speed: How quickly can you get the designation, certificate, and label block? Is the process digital and efficient?
• Exclusions: Most providers do not write your safety report (CPSR) or act as importer/distributor. Legal advice is usually extra. Check for clear exclusions in the service agreement.

Below is a comparison of included/not included/extra fees for each provider:

Always request a detailed quote and service agreement before committing.

What the Price Really Includes and Hidden Costs

Understanding what is included in the published price is essential to avoid unexpected costs. Providers may structure their fees differently:

• Per product vs. per range: Some providers (like REP27) price by the number of products or formulas, counting all sizes of the same formula as one product. Others may charge per SKU or per notification.
• Included services: REP27’s published price includes all required RP duties for up to 5 products: PIF holding, CPNP notification (optional), label/CPSR/PIF review, authority contact, and serious undesirable effects reporting. UK RP is available as an add-on. Certified Cosmetics and Lexora publish annual prices but do not specify if CPNP notification or mid-year product additions incur extra fees—always ask for details.
• Hidden costs: Watch for charges for additional products, CPNP notifications, or changes mid-year. Some providers may charge for document review, legal advice, or urgent requests. Always check the contract for notice periods, liability limits, and transfer fees if you switch providers.

Request a full breakdown of what is included and what is not before signing. If you plan to expand your product line or sell in both EU and UK, clarify the cost for adding products or markets in advance.

How Appointment Works: Step by Step

1. Identify products: List all cosmetics and perfumes (by formula) you plan to sell in the EU/UK. Remember: several sizes of the same formula count as one product with REP27.
2. Prepare documentation: Gather your Product Information File (PIF) and Cosmetic Product Safety Report (CPSR) for each product. The CPSR must be signed by a qualified safety assessor—this is not done by the RP.
3. Request quotes: Contact providers and request a detailed quote. Ask for all included/excluded services and extra fees in writing.
4. Sign agreement: Complete the provider’s online form, sign the designation/mandate electronically, and pay the invoice. With REP27, you get the label block and certificate immediately after agreement.
5. Submit documentation: Upload your PIF, CPSR, and label artwork to the provider’s portal. The RP reviews these for compliance before accepting each product.
6. Receive confirmation: Once accepted, the provider issues the signed designation, certificate with QR code, and label block. You can print labels and prepare for sale.
7. CPNP/SCPN notification: Each product must be notified on the EU CPNP portal (and UK SCPN if selling in the UK). REP27 can file notifications for you or you can do it yourself.
8. Start selling: Products can go on sale once all above steps are complete and the RP has accepted the product in writing.

With REP27, the process is digital, and documentation is issued rapidly, allowing you to print labels while safety reports are finalized. For other providers, ask about their process and timelines.

Risks, Fines, and What Happens If You Skip It

Failing to appoint an EU Responsible Person exposes your business to significant risks:

• Market access: Without an RP, your products cannot be legally sold in the EU. Marketplaces like Amazon and Etsy may remove your listings, and customs can block your shipments.
• Enforcement: National authorities can inspect your products, request documentation, and impose administrative measures or fines. For similar roles (e.g., GDPR Article 27), fines can reach up to €10 million or 2% of worldwide turnover. The Responsible Person is the first point of contact for authorities in case of safety concerns, recalls, or consumer complaints.
• Reputation: Non-compliance can damage your brand’s reputation and relationships with distributors and retailers. Products may be subject to recall or destruction at your expense.
• Operational delays: If you are found non-compliant, you may face delays while you appoint an RP and update labels, documentation, and notifications.

Appointing an RP is not optional—every cosmetic product placed on the EU market must have one. The same applies to the UK after Brexit. If your EU importer or distributor is not willing to act as RP, you must appoint an independent provider before you can legally sell.

Decision Matrix: Do You Need an EU Responsible Person?

This matrix covers company size, country, and sales channel. There are no exemptions for small brands or online-only sales: if you sell to EU consumers, you need an RP.

Checklist: How to Appoint an EU Responsible Person Today

1. List all cosmetic products/formulas for EU/UK sale.
2. Prepare Product Information Files (PIF) and safety reports (CPSR) for each product.
3. Request quotes from at least two providers; ask for all included/excluded services in writing.
4. Check provider's EU establishment and published price.
5. Sign the designation/mandate form and submit required documentation.
6. Receive designation, certificate, and label block.
7. Notify each product on CPNP (EU) or SCPN (UK).
8. Print labels and start selling after approval.

Tip: If you plan to add products later, clarify the process and cost for mid-year additions before signing.

What Providers Usually Do Not Say

• Safety report (CPSR): Most providers do not write your safety report. You must hire a qualified safety assessor separately. The RP reviews the CPSR but does not create it.
• Importer/distributor role: The RP does not act as importer, distributor, or warehouse. They do not handle customs clearance or logistics.
• Extra fees: Some providers charge extra for each CPNP notification, mid-year product additions, or urgent requests. Always ask for a full fee schedule.
• Notice periods and liability: Contracts may include notice periods for termination, liability limits, and requirements for transferring documentation if you switch providers. Read the service agreement carefully.
• Independence: If your EU importer or distributor is willing to act as RP, you do not need an independent provider. However, most brands prefer an independent RP to avoid conflicts of interest and retain control.

Realistic Scenarios: Which Route to Compliance?

• US SaaS selling perfume on Amazon EU: The company must appoint an EU Responsible Person, prepare a PIF and CPSR for each perfume, and notify each product on the CPNP. REP27 can provide the RP service, review documents, and issue the required label block. The company cannot sell until all steps are complete.
• Chinese Amazon seller of skincare: Needs an EU RP, label block, PIF, CPSR, and CPNP notification. If selling in the UK, also needs a UK RP and SCPN notification. REP27 offers both services as a combined plan. The seller must ensure all documentation is ready before listing products.
• UK online shop selling to EU: After Brexit, the shop must appoint both an EU RP and a UK RP. REP27 offers both, with separate addresses for label compliance. Products must be notified on both CPNP and SCPN, and the shop must update packaging accordingly.

In all cases, the simplest compliant route is to prepare all documentation in advance, appoint an RP covering all required markets, and ensure notifications are filed before selling.