EU Responsible Person for cosmetics: what the role covers and how to choose one

Every cosmetic product sold in the European Union needs a Responsible Person: a company or individual established in the EU who answers for the product. For brands from the US, the UK, Korea or anywhere else outside the EU, choosing that person is one of the first decisions of a European launch, and one of the most underestimated.

What the law says

The EU Cosmetics Regulation (Regulation (EC) No 1223/2009) is clear: a cosmetic product may only be placed on the EU market if a Responsible Person established in the EU has been designated for it (Article 4). Their name and address must appear on the label (Article 19).

Who that is depends on where the product comes from:

• Made in the EU: the manufacturer established in the EU is the Responsible Person, unless it appoints someone else in writing.
• Imported into the EU: the importer is the Responsible Person for that product, unless it appoints someone else in writing.
• Sold under a distributor’s own name or changed by a distributor: in some cases the distributor becomes the Responsible Person, for example when it places the product on the market under its own name or trademark, or modifies it in a way that could affect compliance.

What the Responsible Person actually does

The role is often treated as a name on a label. It is a legal role with real obligations. The Responsible Person ensures that each product complies with the Regulation (Article 5), which in practice means:

• Product Information File (PIF). Keeping the file for each product, with the product description, safety report, manufacturing method, proof of claimed effects and animal testing data, available at the address on the label for ten years after the last batch was placed on the market (Article 11).
• Safety assessment. Making sure a Cosmetic Product Safety Report exists for every product, prepared by a qualified safety assessor (Article 10 and Annex I).
• CPNP notification. Notifying every product in the Cosmetic Products Notification Portal before it is placed on the market (Article 13).
• Labelling. Checking that labels meet the EU requirements, including ingredients, function, batch number, durability and precautions in the language required by each member state (Article 19).
• Serious undesirable effects. Reporting serious undesirable effects to the national authorities without delay (Article 23).
• Corrective action. Taking products off the market or recalling them if they do not comply, and cooperating with the authorities.

Why marketplaces care

Since the General Product Safety Regulation (EU) 2023/988 started to apply on 13 December 2024, marketplaces ask sellers for the details of the economic operator responsible for each product, plus safety information and warnings. On Amazon, bol and Kaufland, missing or inconsistent Responsible Person data is one of the most common reasons why a cosmetic listing is blocked or never goes live. The name on the label, in the PIF, in the CPNP and in the marketplace backend should match.

Seven questions to ask before you appoint one

1. Is the company established in an EU member state, and which address will appear on your label?
2. Does it have experience with your product category, for example sunscreen, fragrance or products for children?
3. Who prepares or reviews the safety report, and is the safety assessor qualified?
4. How and where is the PIF stored, and how quickly can it be shown to an authority?
5. How are serious undesirable effects handled, including outside office hours?
6. What does it cost per product and per year, and what is included: CPNP, label review, PIF updates, marketplace support?
7. What happens if you change Responsible Person later? A new name means new labels, so plan the exit before you sign.

Common mistakes

• Printing labels before the Responsible Person is confirmed.
• Assuming a UK Responsible Person also covers the EU. Since Brexit, Great Britain has its own rules and its own notification system.
• Using a different company name on the label, in the CPNP and on the marketplace.
• Treating the PIF as a one-time task. It must be kept up to date when formulas, suppliers or claims change.

How this fits into an EU launch

The Responsible Person is only one step. A European launch also needs EU labelling in the right languages, GPSR details for the marketplaces, packaging registrations (EPR) in countries such as Germany and France, a trademark to unlock brand protection tools and stock inside the EU. As a Dutch company, KOD can act as your EU Responsible Person and work through the rest of this list with you.

Sources: Regulation (EC) No 1223/2009 on cosmetic products, Articles 4, 5, 10, 11, 13, 19 and 23; Regulation (EU) 2023/988 on general product safety. This article is general information and not legal or regulatory advice. Requirements depend on the product.