For contract manufacturers, labs and distributors
Many brands list their manufacturer as their "EU responsible person" — the company that answers for the product in the EU. Not all of them ask first.
"The product is in contact with food, and if there is any safety issue, we appear as the responsible party"
— a seller on the Amazon EU seller forum, having found their own details published as someone else's responsible person
That seller's product is not a cosmetic. We quote it because it is the clearest public example of a company finding out it had been named without agreeing to it.
What you take on if you are named
The responsible person has to:
- keep the product information file — the folder of documents behind the product (Art. 11);
- register the product in the EU's cosmetics portal, CPNP (Art. 13(1));
- have their name and address printed on every unit (Art. 19(1)(a)).
The full list of duties is in Art. 5.
If you make products in the EU for other people's brands, this can land on you by default. The law makes the EU manufacturer the responsible person, unless a written agreement (a "mandate") names someone else (Art. 4(3)). How Art. 4 decides who holds the role →
Which of your documents the brand can use
You probably already hold much of what a brand needs. Here is how each document is used:
| What you hold | Can it go into the brand's file? |
|---|---|
| Master formula and batch sheets | Yes. The safety assessment is built on them, including blends |
| Specifications and certificates of analysis (CoAs) | Yes, for the batch that matches the formula |
| Good manufacturing practice (GMP) records | They support the manufacturing section of the file (Art. 11(2)(c)), but do not replace the written description of how the product is made |
| Stability and preservative (challenge) test results | Yes, and they are expensive to repeat |
| Your own in-house safety opinion | We read it, but we do not simply accept it. A qualified person still has to sign the safety report (Art. 10) |
| Your name in the "responsible person" field | Only where Art. 4 puts it there, or where you agreed in writing |
Your supplier names stay out of the report
We remove supplier names from the safety assessment we deliver. The product information file still keeps the documents you send, each logged with a digital fingerprint (a hash), so there is a record of exactly what came in. Who may see that folder is something you agree in the contract.
We do not develop formulas
We assess products and keep the files. We do not sell formulation work. Before you share a formula with us, you will have in writing what it may be used for.
How we can work together
- Send your brands to us for the safety assessment, the product file and a check of their marketing claims. This work has to be done whoever ends up as the responsible person. If a document is missing, we tell you which one.
- Appoint us as the EU responsible person instead of taking the role yourself, by written mandate. Not sure whether it should be you or us? Nine questions to ask any responsible person →
- Talk to us about referrals: send us the details →
You get one list, not a stream of emails. Your customer signs in to our client portal and sees exactly which documents their product needs, each with the reason. The document request is written so they can forward it to you as it is. Once the last document is in and the formula is declared, the signed safety report usually follows within 3 working days.
Prices: registration starts at €345. Acting as Responsible Person costs €360 per product, per year across the EU. What each price covers →
Get a fixed quote → · Check a customer's listing, free →
Manufacturing in Korea rather than the EU? The situation is different. For Korean brands →
Questions people ask
My details were printed as the responsible person and I never agreed to it. What do I do?
First, write down the facts: which product, which listing, and what the pack says. Then compare that with Art. 4. If you make the product in the EU, Art. 4(3) may make you the responsible person whether or not anyone asked you. We can review what has been published. We cannot give legal advice.
Will you compete with us?
We sell safety assessments and keep product files. We do not develop formulas.
Tell us the product, the variants and the markets — a fixed quote in writing.