1. Introduction

A UK Responsible Person (RP) is the legally designated entity guaranteeing compliance of all cosmetic products sold in Great Britain with the UK Cosmetic Regulation 2020 (SI 2020/1466). The RP acts as the official regulatory liaison between manufacturers, importers, and the Office for Product Safety and Standards (OPSS) — ensuring products sold on the market are safe, correctly labelled, and fully compliant with legal standards.

For cosmetic brands not based in the United Kingdom, appointing a UK Responsible Person is a legal requirement before marketing or distributing any cosmetic products in Great Britain. Phoenix Safety Consultants provides integrated Responsible Person services combining scientific expertise and regulatory precision — from product notification through to post-market surveillance.

2. Regulatory Framework

Since the UK’s withdrawal from the EU, all cosmetic products sold in England, Scotland, and Wales are governed under the UK Cosmetic Regulation 2020 (SI 2020/1466). This legislation mirrors the EU Regulation (EC) No 1223/2009, with adaptations for the standalone UK framework.

Under Article 4 and Schedule 34 of the regulation, every cosmetic product must have a Responsible Person within the UK. The RP is fully accountable for product safety and documentation, acting as the primary contact for enforcement authorities.

The Office for Product Safety and Standards (OPSS), under the UK Department for Business and Trade, is the national competent authority responsible for cosmetic product safety oversight.

Following Brexit, the EU CPNP (Cosmetic Product Notification Portal) was replaced by the Submit Cosmetic Product Notification (SCPN) system. The appointed RP must submit notifications via the SCPN before products can be sold in the UK market. This shift requires higher levels of technical precision and current awareness of evolving UK legislation.

3. Who Needs a UK Responsible Person

Under Great Britain’s regulations, a Responsible Person (RP) must be appointed for all non-UK businesses — including those based in the EU, USA, Canada, and Asia — seeking to sell cosmetics in the UK. Appointment must be documented in writing prior to product placement on the UK market.

• Non-UK manufacturers exporting finished cosmetic products to Great Britain.
• Private-label and contract manufacturers supplying third-party brands.
• Distributors or importers placing products in the UK market.
• UK subsidiaries representing global brands requiring local compliance management.

Without an appointed UK RP, products cannot be notified via the SCPN portal, and may be refused by retailers or distributors due to non-compliance risk.

4. Core Responsibilities of the UK Responsible Person

The UK RP performs critical functions to ensure ongoing compliance under Schedule 34 of the UK Cosmetic Regulation 2020:

• Verification of Compliance: Ensuring every cosmetic product meets safety and composition requirements, including Annex II (prohibited ingredients) and Annex III–VI (restricted substances, preservatives, UV filters, and colorants).
• PIF Maintenance: Maintaining complete and current Product Information Files (PIFs) including CPSRs, manufacturing records, and proof of efficacy claims.
• CPSR Verification: Confirming that each cosmetic product has a valid Cosmetic Product Safety Report (CPSR) prepared by a qualified assessor.
• SCPN Notification: Submitting product information through the UK Submit Cosmetic Product Notification portal prior to market entry.
• Labelling and Claims Compliance: Reviewing all product labels for Article 19 compliance — including ingredient lists, warnings, Responsible Person details, and durability symbols.
• Post-Market Surveillance: Monitoring product safety, investigating complaints, reporting Serious Undesirable Effects (SUEs) to the OPSS, and assisting with audits or recalls.

The RP serves as the cornerstone of accountability and traceability for cosmetics compliance in the United Kingdom.

5. Phoenix Safety Consultants’ Expertise

Phoenix Safety Consultants offers comprehensive Responsible Person services across the UK. Our approach combines scientific integrity, legal precision, and operational experience. Each consultant holds advanced qualifications in toxicology, chemistry, and cosmetic safety management.

We guarantee compliance with both UK Cosmetic Regulation 2020 and EU Regulation (EC) No 1223/2009, ensuring full cross-market validity. Our Responsible Person services include:

• Acting as the official UK Responsible Person for global cosmetic brands.
• Managing SCPN submissions with complete data integrity and traceability.
• Reviewing PIFs and CPSRs for full regulatory compliance.
• Aligning labelling and documentation consistency between UK and EU markets.
• Supporting clients with post-market reporting, SUE management, and audit representation.
• Providing ongoing compliance monitoring aligned with OPSS updates and legislative changes.

Our cross-functional team ensures each product represented under Phoenix’s RP service meets the highest standards of legal and scientific compliance throughout its market lifecycle.

6. Documentation and Process

To designate Phoenix Safety Consultants as your UK Responsible Person, we require the following documentation and data for verification and SCPN submission:

• Product formulation (INCI list with percentages).
• Safety Data Sheets (SDS) for all raw materials and components.
• Cosmetic Product Safety Report (CPSR).
• Product Information File (PIF) including manufacturing and testing documentation.
• Label and packaging artwork.
• High-resolution product images.
• Manufacturer/distributor details (company name, address, contact).
• Emergency contact and safety communication details.

After document receipt, Phoenix will:

• Evaluate the regulatory adequacy of submissions.
• Conduct compliance cross-checks against UK Cosmetic Regulation 2020.
• File SCPN submissions via the OPSS system.
• Provide official confirmation naming Phoenix Safety Consultants as your appointed UK Responsible Person.

Our process ensures complete regulatory confidence, market access, and peace of mind.

7. Benefits of Appointing Phoenix

• Legal Compliance: Full adherence to the UK Cosmetic Regulation 2020 and Schedule 34 requirements.
• Authority Representation: Phoenix manages all communications with the OPSS on your behalf.
• Documentation Integrity: Every CPSR, PIF, and SCPN submission is verified for accuracy and compliance.
• Risk Reduction: Prevent enforcement actions, import delays, and product removals through proactive compliance.
• Ongoing Support: Continuous advisory and compliance updates to reflect new OPSS or legislative revisions.

As your compliance partner, Phoenix Safety Consultants ensures you avoid any roadblocks to market access while maintaining complete regulatory confidence.

8. Pricing

Service Range: £800 – £2,000 per product line, depending on complexity, documentation volume, and number of variants covered.

With Phoenix Safety Consultants as your UK Responsible Person, your brand will operate in full alignment with all post-Brexit UK cosmetic regulations.

→ Appoint Phoenix as your UK Responsible Person
→ Learn More About SCPN and Cosmetic Notifications
→ Explore CPSR and PIF Support Services