If you sell cosmetics in Great Britain, the law requires a UK-established Responsible Person (RP) for every product. Since Brexit this has become one of the most common compliance gaps for brands especially EU makers selling into the UK, and UK brands importing products to sell on. This guide explains exactly when you need a UK RP and who can take on the role.
For the wider picture, see our pillar guide to what a Responsible Person is. Here we focus on the UK requirement specifically.
Do you need a UK Responsible Person?
If your cosmetic is placed on the Great Britain market (England, Scotland and Wales), then yes you must have a Responsible Person established in the UK. This is a legal requirement under the UK Cosmetics Regulation, which retained the EU rules after Brexit. There is no threshold or exemption: it applies whether you sell one product or thousands, online or in shops, as a hobby brand or a large company.
The UK RP's name and a UK address must appear on the product label, and the RP must hold the product's compliance documents. Without a designated UK RP, the product is not compliant and should not be on sale in Great Britain.
What changed after Brexit?
Before Brexit, a single EU-established Responsible Person could cover the UK as part of the EU market. That is no longer the case. Great Britain is now a separate market with its own rules, and it requires its own UK-based RP. An EU company can no longer act as the RP for products sold in Great Britain, and the product's notification must be made on the UK's own portal rather than the EU system.
This is why so many EU brands selling into the UK suddenly needed a UK presence, and why many appoint a third-party UK RP service rather than set up their own UK entity. The reverse is also true: a UK brand selling into the EU now needs a separate EU RP, which we cover in our EU Responsible Person guide.
Who can be your UK Responsible Person?
The UK RP must be established in the UK, and depending on your situation it could be:
- You, if your business is established in the UK and you place your own products on the GB market.
- The UK importer, who automatically becomes the RP for products brought into Great Britain, unless another UK entity is designated.
- A UK distributor, where they sell under their own brand or modify the product.
- A third-party UK RP service, appointed by written mandate common for overseas brands with no UK base.
For a UK-based indie maker selling their own products in Great Britain, the usual answer is that you can be your own UK RP. The complication arises for overseas sellers, or where products are imported, which is where a designated UK RP becomes necessary. To explore whether you qualify to act for yourself, see can I be my own Responsible Person?.
What your UK RP is responsible for
A UK RP is not just a name on a label. They must ensure each product has a valid CPSR and a Product Information File, that the product is notified to the UK authorities through the SCPN service see our SCPN guide and that the labelling meets UK requirements. They must also keep records, respond to the Office for Product Safety and Standards (OPSS), and act on any safety issues.
This is an ongoing role, not a one-off task. Whoever acts as your UK RP carries real legal accountability for the product the whole time it is on sale, so it should never be treated as a box to tick. The full scope is set out in our guide to RP obligations and penalties.
Selling on UK marketplaces
Marketplaces such as Amazon UK and Etsy increasingly ask sellers to demonstrate compliance, and a missing or invalid UK RP is a common reason listings are challenged or removed. Platforms are under growing pressure to ensure the products they host are compliant, so having a properly designated UK RP and the supporting documents is not only a legal duty but increasingly a practical condition of selling at all.
If you sell across several UK channels, the same UK RP and documentation cover them all you do not need a separate RP per platform, only per product and market.
Importing cosmetics into Great Britain
Importing changes the picture significantly. If you bring a cosmetic into Great Britain from outside the UK including from the EU you generally become the Responsible Person for it by default, unless another UK entity is designated. That makes you legally accountable for a product you may not have formulated, so you need access to its full compliance dossier: the CPSR, the PIF, the ingredient data and the documentation behind any claims. Importing on the assumption that the overseas brand's paperwork automatically covers you in the UK is a common and risky error.
This is why brands buying in stock from abroad should agree, in writing and up front, who holds UK RP responsibility and who supplies the underlying data. If the overseas manufacturer will not share what you need to meet your duties, that is a serious problem to resolve before you import, not after the stock arrives.
How much does a UK Responsible Person cost?
Costs vary with how much work the role involves and whether you also need the underlying documents prepared. Acting as your own UK RP carries no service fee, but you still need a valid CPSR, PIF and SCPN notification behind each product and CPSRs start from around £55 for a simple product, as set out in our CPSR cost guide. Appointing a third-party UK RP adds a service element, usually charged per product or as an ongoing arrangement.
The sensible way to think about it is total cost of compliance rather than the RP line alone. A founder who is organised and sells only in the UK may spend very little beyond the assessment. A brand importing stock or expanding across markets will find that a service, while an added cost, removes a great deal of risk and administration. Weigh the fee against the time and liability you would otherwise carry yourself.
How to appoint or switch a UK RP
Putting a UK Responsible Person in place is a defined process rather than an informal arrangement. If you appoint a third party, there must be a written mandate confirming they accept the role, and they must have access to your compliance dossier for each product the CPSR, the PIF, the SCPN notification details and your labelling. The RP's UK name and address then appear on the pack, and they become the point of contact for the authorities. Skipping the written mandate, or naming an RP who has never seen your documents, leaves a gap that an inspection will quickly expose.
Switching RP is also straightforward when handled properly. The incoming RP takes over the dossier, the label is updated to show their details, and the notification is amended so the records match. The key is that nothing falls through the cracks during the change: at every moment a product is on sale, a valid UK RP must be designated and the documents must reflect who that is. Planning the handover avoids a window where the product is technically non-compliant.
UK Responsible Person checklist
- Confirm your products are sold on the Great Britain market.
- Designate a UK-established RP for each product.
- Put the UK RP name and address on the label.
- Ensure the RP holds the CPSR, PIF and SCPN notification.
- Have a written mandate if using a third-party UK RP.
Selling in Great Britain? Phoenix Safety Consultants can act as your UK Responsible Person and handle your CPSR, PIF, SCPN notification and labelling — so your products are fully compliant for the UK market.
Get a UK Responsible Person →Frequently asked questions
Do I need a UK Responsible Person to sell cosmetics in Britain?
Yes. Any cosmetic placed on the Great Britain market must have a UK-established Responsible Person, with their name and UK address on the label. There is no small-brand exemption.
Can an EU company be my UK Responsible Person?
No. Since Brexit, the UK RP must be established in the UK. An EU-based entity can no longer act as the RP for products sold in Great Britain.
Can I be my own UK Responsible Person?
Yes, if your business is established in the UK and you place your own products on the GB market. Overseas brands generally need a UK-based importer or a third-party UK RP service.
Does Northern Ireland need a UK Responsible Person?
Northern Ireland follows EU rules under the Windsor Framework, so the position differs from Great Britain. Products there align with the EU RP and notification system.
Do marketplaces check for a UK Responsible Person?
Increasingly yes. UK marketplaces may ask for proof of compliance, and a missing or invalid UK RP is a common reason listings are challenged or removed.
References: UK Cosmetics Regulation (retained Regulation (EC) No 1223/2009); UK Cosmetic Products Enforcement Regulations 2013; OPSS guidance on the Responsible Person and SCPN. General information only, not legal advice.
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