Whose address goes on the label — the responsible person's, and what that means for you
Yes. Every cosmetic sold in the EU must carry the name and address of its responsible person on the container and the packaging (Art. 19(1)(a), Reg. (EC) 1223/2009). Whose address that is depends on who is designated responsible person — not on who made the product, and not on who designed the label.
What the label has to show, and in what form
Art. 19(1) requires the container and the packaging to bear the information "in indelible, easily legible and visible lettering". Point (a) of that paragraph sets out the responsible person's part of it, in four sentences:
the name or registered name and the address of the responsible person. Such information may be abbreviated in so far as the abbreviation makes it possible to identify that person and his address. If several addresses are indicated, the one where the responsible person makes readily available the product information file shall be highlighted. The country of origin shall be specified for imported cosmetic products; — Art. 19(1)(a), Reg. (EC) 1223/2009
So, in practice:
- Name and address of the responsible person — on the container and on the packaging.
- Abbreviation is allowed, as long as the person and the address can still be identified.
- More than one address on the pack? Highlight the one where the product information file is kept.
- Imported product? The country of origin goes on too.
Does my home address have to go on it?
Only for as long as you are the designated responsible person. Designate someone established in the Union and their registered address is the one printed.
Who holds the role is decided by Art. 4. The manufacturer established in the Union is the responsible person unless it designates someone else by written mandate; for an imported product the importer is, 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 and accept in writing (Art. 4(3)–(6), Reg. (EC) 1223/2009).
Check my product — free
Paste the product's public listing URL. We check which of the eight obligations are visibly met — free, while you wait — a screen of the public words, not a safety assessment.
No public page, or the list is only on the pack? Paste it instead
What changes when you appoint a responsible person
Their address goes on the pack in place of yours. The product information file is kept at that address, readily accessible (Art. 11(3)). And it is the address an authority writes to.
Is a PO box or a service address enough?
The Regulation asks for the responsible person's address, and the product information file has to be readily accessible at the address indicated on the label (Art. 11(3)). An address where no one can hand over the file does not do that job.
What the yearly fee buys
Per product, across the EU. We act as your Responsible Person: the named contact inside the EU that the law requires you to have, and the one customs, retailers and inspectors write to. We watch the EU registers for rule changes that touch your product, and tell you when one does. The price is published; how the role works is on the Responsible Person page, and what else the label must carry is under labelling.
Questions people ask
Can the manufacturer's address be on the pack instead?
Only if the manufacturer is the designated responsible person (Art. 19(1)(a)).
Do I need to reprint my labels when I change responsible person?
Yes. The address on the pack has to be the responsible person's (Art. 19(1)(a)).
Is the country of origin required on the label?
For imported cosmetic products, yes (Art. 19(1)(a)).
Start with the free check — see what your listing is missing, while you wait.