The EU Responsible Person
This is the obligation people discover last and cannot work around.
The fact
"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 provider established outside the Union cannot itself be an EU responsible person, however good its safety report is.
How Art. 4 places the role
- EU manufacturer — is the responsible person, and may designate someone established in the Union by written mandate (Art. 4(3)).
- Product made in the Union by a manufacturer outside it — the manufacturer must designate someone established in the Union (Art. 4(4)).
- Imported product — each importer is the responsible person, unless they designate someone (Art. 4(5)).
- Distributor — is the responsible person where they place the product on the market under their own name or trademark, or modify a product already on the market in a way that may affect its compliance (Art. 4(6)). Translating a label is not such a modification.
Most small brands outside the Union make their products outside it too, so Art. 4(5) applies: whoever imports the product is the responsible person, holds the file and has their address on the pack — unless a person is designated by written mandate. That is why most of them arrange the mandate.
We can be appointed as your EU Responsible Person, by written mandate. The safety report and the file are the work that comes first.
What the role actually is
The designated person holds the file (Art. 11), submits the CPNP notification (Art. 13(1)), is named on the pack (Art. 19(1)(a)), and is the address an authority writes to. The duties sit in Art. 5.
That list does not include signing the safety report. That is Art. 10, and the person who signs it must hold a qualification in Art. 10(2). David Vandevoort signs our safety reports. The Responsible Person is identified separately in the written mandate.
The pack must bear "the name or registered name and the address of the responsible person" (Art. 19(1)(a)). Designate yourself and your address goes on the jar. Designate us and ours does.
A mandate will be accepted only in writing, only for products whose file we hold, and only where we are prepared to defend what is in it. Switching from another responsible person → · Nine questions to ask any responsible person →
The mandate is €360 per product, per year across the EU, invoiced a year ahead. If you already are the designated Responsible Person and only want us to hold the file and watch the registers, that line is €240 per product, per year. The lines we charge, and what moves them →
Questions people ask
Does a UK CPSR or a UK Responsible Person cover the EU?
A responsible person established in Great Britain is not designated within the Community. What of a UK report can be reused is a question about your document.
Will my home address have to go on the label?
Only where you are the designated responsible person (Art. 19(1)(a)). Whose address goes on the label, in full →
Will appointing you get my Amazon listing reinstated?
We can give you a complete file, and act as your Responsible Person by written mandate. What a marketplace does with that is the marketplace's decision. The field a marketplace asks about is often the seller-side role under Reg. (EU) 2023/988, which is a different obligation.
Tell us the product, the variants and the markets — a fixed quote in writing.