What Is a Responsible Person for Cosmetics? (UK & EU Guide)

What is a Responsible Person?

Why does every cosmetic need a Responsible Person?

The Responsible Person exists so that there is always a clearly identifiable, locally based entity that authorities can hold to account. If a regulator has a safety concern, if a consumer is harmed, or if a product needs to be recalled, they need someone within their jurisdiction who is legally answerable not a distant manufacturer in another country. The RP is that point of contact and accountability.

This is why the RP's name and address must appear on the product label. A consumer or inspector should be able to look at any cosmetic and immediately know who is legally responsible for it. Selling a product with no designated RP or with an RP based in the wrong territory is a serious compliance failure that can lead to the product being removed from sale.

Who can be the Responsible Person?

The regulation sets out who can take on the role, and it depends on your position in the supply chain:

• The manufacturer, where they are established in the market and place the product on it themselves.

• The importer, who is automatically the RP for any product they bring in from outside the market, unless they designate someone else.

• A distributor, where they sell a product under their own name or brand, or modify a product already on the market.

• A designated third party, appointed by written mandate for example a specialist RP service that acts on a brand's behalf.

For a UK indie brand selling its own products in the UK, the maker is usually established in the UK and can be their own RP. The picture changes the moment you sell across a border which is where many founders need a third-party RP. We cover the specifics in our guides to whether you need a UK RP and an EU RP.

What does the Responsible Person actually do?

The role is not a rubber stamp it carries real, ongoing duties. The Responsible Person must ensure that the safety assessment has been carried out and a valid CPSR exists, that the Product Information File is kept and made available to authorities, that the product is notified on the correct portal, and that the labelling complies in every detail. They must also keep records, respond to authority requests, and take corrective action if a product is found to be non compliant.

The duties continue throughout the time the product is on sale. The RP must monitor for and report serious undesirable effects, cooperate with market surveillance, and act if new information affects the product's safety. In other words, the RP owns compliance from launch to withdrawal, not just at the point of sale. We break these duties down fully in our guide to Responsible Person obligations and penalties.

Responsible Person vs manufacturer vs distributor

These roles often overlap but are not the same. The manufacturer makes the product; the distributor sells or supplies it without changing it; the Responsible Person is the one legally accountable for compliance. A single business can hold more than one role a UK maker who formulates, sells and is established in the UK is manufacturer, distributor and RP all at once. But when products cross borders or are sold under another brand, the roles separate, and it becomes essential to know exactly who is the RP for each market.

Getting this clear matters because the RP carries the legal liability. If you are a distributor selling someone else's product unchanged, you are generally not the RP but if you rebrand it as your own, you may become it. Understanding where you sit in the chain is the first step to knowing your obligations.

The Responsible Person after Brexit

Brexit split a single market into two. A cosmetic sold in Great Britain now needs a UK-established RP, while the same product sold in the EU needs an EU-established RP. Northern Ireland follows EU rules under the Windsor Framework. In practice this means many brands now need two Responsible Persons one for each market even though the product itself is identical. This is one of the most significant practical changes the cosmetic sector has had to absorb, and it is a common reason brands turn to a third-party RP service.

If you only sell in one market today but plan to expand, it is worth understanding the RP requirement for your target market early, because it affects your labelling, your notification and your costs.

Common Responsible Person mistakes

The most frequent mistake is assuming a single Responsible Person can cover both the UK and the EU. Since Brexit this is almost never true, and brands that carry only one RP for both markets are non-compliant in the other. A close second is selling on the assumption that a small or handmade operation is somehow exempt it is not; the RP requirement applies to every cosmetic regardless of scale. A third is putting an overseas address on the label as the RP when that entity is not actually established in the market of sale.

Another quiet failure is treating the RP as a one-off setup rather than an ongoing role. Brands appoint an RP at launch, then change a formulation, supplier or claim without telling them, leaving the documentation out of step with the product actually on sale. Because the RP is accountable for the product as sold, these drifts matter. Keeping your RP informed of changes is part of staying compliant, not an optional courtesy.

How a third-party RP service works

When you cannot or would rather not act as your own Responsible Person, you appoint a third party by written mandate to take on the role for a given market. The service is named on your label as the RP, holds or has access to your compliance dossier, handles notification, and acts as the point of contact for authorities. It is an established, entirely legitimate route used by brands of every size, and it is the standard solution for selling into a market where you have no local establishment.

A good RP service does more than lend an address. It checks that your CPSR, PIF, notification and labelling are genuinely in order, flags problems before they reach an authority, and keeps your products aligned as the rules evolve. For a brand selling across the UK and EU, using a service for the market you cannot cover yourself is often the simplest and safest way to stay compliant on both sides of the border.

What to check about your Responsible Person

• Is an RP designated for every product you sell?

• Is the RP established in the correct market (UK for GB, EU for the EU)?

• Does the RP's name and address appear on the label?

• Does the RP hold the CPSR, PIF and notification for each product?

• Is there a written mandate in place if a third party acts as your RP?

Frequently asked questions

What is a Responsible Person for cosmetics?

It is the company or individual legally accountable for ensuring a cosmetic meets all requirements before and after sale. Every cosmetic on the UK or EU market must have one, established in that market, with their details on the label.

Does every cosmetic need a Responsible Person?

Yes. A cosmetic may only be placed on the market once an RP has been designated for it. There is no exemption for small or handmade brands.

Can the Responsible Person be based in any country?

No. The RP must be established in the market where the product is sold — the UK for Great Britain, and an EU member state for the EU. After Brexit, one entity can rarely cover both.

Is the manufacturer always the Responsible Person?

Not always. The manufacturer is the RP only if established in the market and placing the product there. Importers, own-brand distributors, or a designated third party can also be the RP depending on the supply chain.

Do I need two Responsible Persons to sell in the UK and EU?

Usually yes. Selling the same product in both markets generally requires a UK-established RP for Great Britain and an EU-established RP for the EU.

References: Regulation (EC) No 1223/2009, Articles 4 and 5 (EUR-Lex); UK Cosmetics Regulation as retained; UK Cosmetic Products Enforcement Regulations 2013; OPSS guidance. General information only, not legal advice.