Amazon has blocked your EU cosmetics listing and is asking for a Responsible Person

What you are looking at

The pattern is consistent enough to describe without quoting anyone. EU listings drop into an inactive, blocked state. A compliance dashboard asks for an EU responsible person. Sellers report an error code, 6039. Documents get uploaded. Sometimes a green tick and an approval label sit above a line of text saying the documents were not approved. Sometimes the case sits open and support replies from a script.

Two things are worth knowing before you read further. Reinstatement is Amazon's decision and no one can sell it to you. But the reason most sellers are still blocked at the third submission is not a judgement about their product — it is that their documents do not agree with each other, and that is fixable without waiting for support to read your case.

One thing to get out of the way early. Great Britain and the EU are not the same case here. A moderator in one of those Amazon threads told sellers that GPSR does not apply to Great Britain and that no action was needed in their UK account, Northern Ireland excepted. That is a statement by a marketplace employee on a forum rather than law — but it tells you something true and useful: a GB seller's experience of this is not evidence about your EU listing, and half the advice circulating is about the wrong territory.

(The pattern above is described rather than quoted: the threads that record it could not be confirmed word for word, so none of it is in quotation marks.)

Two regimes, and the field is asking about one of them

Amazon's compliance field is doing two jobs at once, and sellers lose time because the two are rarely separated.

Regulation (EU) 2023/988 — the General Product Safety Regulation. It has applied since 13 December 2024 (Art. 52, Reg. (EU) 2023/988). It is why every seller of every kind of product is suddenly being asked to name an economic operator established in the Union. This is a seller-side, marketplace-facing field. It is broad, it is shallow, and it is the one most of the forum noise is about.

Regulation (EC) No 1223/2009 — the Cosmetics Regulation. Older, narrower, and much deeper. For a cosmetic it requires, before the product is placed on the Union market:

• a responsible person designated within the Union — "Only cosmetic products for which a legal or natural person is designated within the Community as 'responsible person' shall be placed on the market" (Art. 4(1));
• a safety assessment and a safety report set out in accordance with Annex I (Art. 10(1));
• a product information file kept for ten years after the last batch was placed on the market (Art. 11(1));
• a notification to the Commission before placing (Art. 13(1));
• a label bearing the responsible person's name and address (Art. 19(1)(a)).

If you sell a cosmetic, both bite. Filling in the GPSR economic-operator field does not give you a responsible person under Art. 4. Having a responsible person under Art. 4 does not, by itself, populate a marketplace form. Sellers routinely do one and assume the other is handled.

Why the second and third submission get rejected too

The most useful thing in the forum evidence is not the opening rejection. It is the pattern of resubmission — documents provided, more documents requested, the same rejection again.

In the threads we read, the resubmissions that fail again describe the same thing: documents that do not agree with each other. That is our reading of the pattern rather than a rule Amazon publishes — so treat the list below as what we would check first, not as what Amazon says it checks.

• The name on the safety report is not the name in the responsible person field.
• The address on the pack artwork is not the responsible person's address (Art. 19(1)(a)).
• The product name on the listing is not the product name on the notification (Art. 13(1)).
• The ingredient list in the listing content is not the ingredient list on the label.
• The file names a responsible person who has never accepted the role in writing.
• The report is generic — bought against somebody else's base recipe — and does not describe the product in the listing.

A reviewer working from a checklist appears to be comparing strings rather than assessing your chemistry. Every mismatch we have seen described ends in a rejection, and each rejection resets the clock.

So the fastest legitimate path is not "send more documents". It is: make one coherent set in which the name, the address, the product identity and the composition are the same in every artefact — and then submit once.

The fastest legitimate path

1. Establish what your product needs, before you buy anything. Is it a cosmetic; what is in it that is restricted; what is the label missing. The free check asks for no email address.
2. Settle the formula. This is the step people skip under deadline pressure, and it is the one that produces a third rejection from the marketplace. If a substance needs a document or a change, we name it before the rest of the set is assembled.
3. Settle the responsible person question. Only a product for which a person is designated within the Union as responsible person may be placed on the market (Art. 4(1)). Under Art. 4(3)–(6): a manufacturer established in the Union is the responsible person unless it designates someone by written mandate; for an imported product the importer is the responsible person unless it designates otherwise; a distributor becomes the responsible person when it places the product under its own name or trademark; and any person established in the Union may be designated by written mandate, which that person accepts in writing. We can be appointed as your EU Responsible Person, by written mandate. How that works →
4. Assemble the file and get the report signed by a person qualified under Art. 10(2).
5. Notify (Art. 13(1)).
6. Reprint or re-artwork the pack so the address on it is the responsible person's (Art. 19(1)(a)).
7. Submit one consistent set and keep a dated record of what was sent.

Steps 1 and 2 are the ones that shorten the whole thing, because they are the ones that tell you whether you have a paperwork problem or a product problem.

What to gather before you start

Under deadline pressure people begin by writing to support. Begin here instead. Every item below is something you will be asked for, and every one you are missing is something to start chasing today.

• The full composition of the product, to substance level, with percentages — not a marketing ingredient list.
• A specification and a certificate of analysis for each raw material, from the supplier.
• An allergen statement for every fragranced material, including essential oils.
• The manufacturing method and a statement on good manufacturing practice from whoever makes it (Art. 11(2)(c), Reg. (EC) 1223/2009).
• Print-ready artwork for the container and the outer packaging, as it is currently printed.
• The exact listing text, including the ingredient list shown on the detail page.
• Any existing safety report, with the name and qualification of whoever signed it.
• Evidence for any claim on the pack or the listing.

If you cannot produce the composition or the raw-material documents, that is the finding, and it is about your supply chain rather than about Amazon. It is also fixable in writing: ask for each item against the article that requires it.

What we will not promise you

We will not tell you that appointing an EU responsible person gets your listing reinstated. Reinstatement is a marketplace decision made against a marketplace checklist that is not published and changes. Treat any promise of reinstatement as a promise about something the person making it does not control.

What we will do is make a set of documents that is internally consistent, that cites the article behind each element, and that survives the next request as well as this one — because the forum evidence is that there is usually a next request.

If something in the formula needs a document or a change, we name it, with the annex entry. The signature follows once that is in the file.

FAQ