EU Responsible Person & Cosmetic Product Notification (CPNP)

What's included in your EU Responsible Person service

Who needs an EU Responsible Person

• UK, US and other non-EU manufacturers and brand owners
• Private-label and contract manufacturers serving multiple brands
• EU importers and distributors who prefer to designate a specialist
• Amazon and online sellers needing EU Responsible Person label details

3-year plan vs renewing every year (1–3 products)

What the EU Responsible Person service does not include

• Writing your CPSR. As your Responsible Person we check that each product has a valid CPSR, but the safety report itself is a separate service. See our CPSR for a single beauty product or the All-in-One CPSR, PIF, SDS & UK/EU Notification.
• Building your Product Information File. We hold and maintain your PIF; if you do not have one yet, order a Product Information File.
• Great Britain. An EU Responsible Person does not cover England, Scotland or Wales. To sell there you also need a UK Responsible Person.
• Products outside your plan. Each plan covers the product band you select: 1–3, 4–10, 10+ or, on the 5-year plan, unlimited products.

How it works

1. Initial consultation We review your product portfolio and your ownership and manufacturing structure.
2. Written mandate and appointment You designate Phoenix as your EU Responsible Person by written mandate, as Article 4 requires, for your chosen term and product band.
3. Fill our Product Information Document Send your CPSR, PIF, label artwork and product data so we can check them.
4. CPNP notification We complete your Article 13 notifications and confirm acceptance.
5. Ongoing compliance support We monitor regulatory changes and maintain your PIF records for the length of your plan.

What is an EU Responsible Person for cosmetics?

An EU Responsible Person for cosmetics is the legal or natural person established in the European Union who is accountable for a cosmetic product's compliance. Article 4 of Regulation (EC) No 1223/2009 states that only cosmetics with a designated Responsible Person may be placed on the EU market, and Article 13 makes that person responsible for the CPNP notification.

An EU-based manufacturer or importer is the Responsible Person by default. A manufacturer based outside the EU, including in Great Britain, the US or elsewhere, must designate an EU-established person by written mandate. Phoenix acts as your EU Responsible Person across CPNP notification, PIF management, label checks and post-market surveillance. Selling in Great Britain too? You also need a UK Responsible Person.

Legal duties of an EU Responsible Person

For each product placed on the EU market, the Responsible Person must ensure compliance with the Regulation (Article 4(2)). In practice that means:

• Product safety: making sure each product is safe (Article 3) and supported by a CPSR under Article 10 and Annex I.
• CPNP notification: notifying the product on the CPNP under Article 13 before it is placed on the market.
• Label and packaging compliance: checking the Article 19 particulars, including the Responsible Person's name and address, nominal content, batch number, precautions and the ingredient list.
• PIF management: keeping the Product Information File readily accessible at the address on the label for 10 years after the last batch is placed on the market (Article 11).
• Ingredient monitoring: tracking prohibited and restricted substances, colourants, preservatives and UV filters against Annexes II–VI.
• Post-market surveillance: notifying the competent authority of serious undesirable effects without delay (Article 23) and coordinating corrective action or recalls.
• Communication with authorities: acting as the official contact point for EU regulators.

Do UK brands need an EU Responsible Person?

Yes. A company established only in Great Britain is outside the EU and cannot act as the EU Responsible Person, so UK brands selling into the EU must appoint one. Without an EU Responsible Person:

• No CPNP notification can be submitted
• Products cannot lawfully be placed on the EU market (Article 4)
• Shipments and marketplace listings can be stopped by customs, retailers or platforms such as Amazon
• You risk enforcement action by national authorities

Northern Ireland follows the EU cosmetics rules: products placed on the NI market need a Responsible Person established in Northern Ireland or the EU and are notified on the CPNP.

Your plan runs for the term and product band you choose above. CPNP notification, PIF management and authority communication are included for each product in your band.

Legal framework

• Article 4, Regulation (EC) No 1223/2009 — only cosmetics with a Responsible Person designated within the EU may be placed on the market; non-EU manufacturers designate one by written mandate
• Article 10 and Annex I — the safety assessment and CPSR
• Article 11 — the PIF is kept for 10 years after the last batch and made readily accessible at the address on the label
• Article 13 — pre-market notification on the CPNP
• Article 19 — labelling, including the Responsible Person's name and address
• Article 23 — notification of serious undesirable effects
• Annexes II–VI — prohibited and restricted substances, colourants, preservatives and UV filters
• ISO 22716 — the harmonised standard for cosmetics Good Manufacturing Practice (Article 8)

Official sources:

• Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
• Cosmetic Products Notification Portal (European Commission)
• Cosmetics rules for Northern Ireland (GOV.UK)

Why brands appoint Phoenix as their EU Responsible Person

• EU-established representation — a Responsible Person based in the EU, as Article 4 requires.
• End-to-end coverage — CPNP, PIF, labels, monitoring and authority liaison in one service.
• Protects your market access — no blocked notifications or stopped listings for want of a Responsible Person.
• Confidential and ready for inspection — your PIF kept accessible to authorities at our EU address.
• Trusted by 1,400+ brands over 14 years, including The Beard Struggle, The Essence Vault, Parfum Fabric and Junaid Jamshed.

Appoint Phoenix as your EU Responsible Person today. Choose your term and product band above, or message us on WhatsApp on +44 7346 009332 if you are unsure which tier fits your range.

Frequently asked questions