Every cosmetic product sold in the EU needs an EU Responsible Person: a company or person established in the EU that answers for the product under Regulation (EC) No 1223/2009. If you are based outside the EU, you appoint one by written mandate (Article 4). It is easy to see this as renting an EU address for the label. It is more than that, and the difference decides when you can start selling.
A producer of argan oil in Morocco recently asked us whether we could act as their Responsible Person for two bottle sizes, 30 ml and 50 ml. The answer was yes, and both sizes fit in the same annual service. But before we could register anything, they needed a complete Product Information File with a valid safety report. That file, not the address, decides when you can start selling.
What an EU Responsible Person for cosmetics does
The EU Responsible Person makes sure each cosmetic product meets the Cosmetics Regulation before and after it reaches the market. If you import cosmetics into the EU yourself, you are automatically the Responsible Person for those products (Article 4(5)). If you are outside the EU, you need someone inside it.
In practice, the Responsible Person:
- keeps the Product Information File available at its EU address for ten years after the last batch is placed on the market (Article 11)
- notifies each product in the Cosmetic Products Notification Portal (CPNP) before it goes on sale (Article 13)
- appears with name and address on the label (Article 19(1)(a))
- takes corrective action, withdraws or recalls a product that does not conform (Article 5(2))
- reports serious undesirable effects to the authorities without delay (Article 23)
- is the contact point when a market surveillance authority asks questions
That is why a serious Responsible Person reviews your documents before putting its name on your packaging. Its address on your label makes it answerable for what is in the bottle.
What you need before registration
Before a Responsible Person can notify your product, you need a complete Product Information File (PIF). Article 11(2) lists what goes in it:
| Part of the PIF | What it is |
|---|---|
| Product description | enough detail to link the file to one specific product |
| Cosmetic Product Safety Report (CPSR) | the safety assessment required by Article 10 and Annex I |
| Manufacturing method and GMP statement | how the product is made, and a statement that it follows good manufacturing practice (Article 8) |
| Proof of claimed effects | evidence for what the label or listing promises, where the nature of the product justifies it |
| Animal testing data | any animal testing done by you or your suppliers for the product or its ingredients |
On top of the PIF, a Responsible Person will ask for the formula and ingredient list, the label or artwork, and supporting evidence for your claims. Claims must follow Regulation (EU) No 655/2013: no medical or therapeutic claims on a cosmetic.
The safety report is the part that takes longest
The CPSR must be signed by a qualified safety assessor: someone with a university qualification in pharmacy, toxicology, medicine or a similar discipline (Article 10(2)). Your manufacturer cannot sign it for you unless they employ such a person, and a Responsible Person does not automatically write it either.
What the report itself must contain, part by part, is explained in our article on the Cosmetic Product Safety Report.
At Westwood we review and store the PIF and the CPSR, but we do not prepare them. You arrange the safety report with a qualified assessor, and we check it before we register the product. We say that upfront, because it is easy to assume the safety report is included somewhere.
Want to know what we need from you? Our EU Responsible Person service for cosmetics lists what the service covers and which documents to send.
CPNP notification as the last step
The CPNP notification is the electronic registration of your product with the European Commission, and it has to happen before the product is placed on the market (Article 13(1)). It covers, among other things, the product category and name, the Responsible Person, the country of origin, the presence of nanomaterials and certain restricted substances, and the frame formulation that poison centres use for medical treatment.
The Responsible Person submits it, and it can only do so once the PIF is complete. It is tempting to see CPNP registration as a form you fill in on day one. In fact it is the final administrative step, after the safety work is done.
What goes into the notification, field by field, is explained in our guide to the CPNP notification.
What goes on the label
Article 19(1) sets the mandatory label information. For an imported product that includes:
- name and address of the EU Responsible Person
- country of origin
- nominal content, by weight or volume
- date of minimum durability, or the period after opening
- precautions for use
- batch number
- function of the product, unless it is clear from how it is presented
- list of ingredients
Our EU contact details go on your packaging only once your product has been accepted under our service. Do not print a Responsible Person's address before that is agreed; reprinting packaging is expensive.
One Responsible Person covers the whole EU
You need one Responsible Person, not one per country. The designation applies to the whole EU market, even if you start by selling in one country. The argan oil producer we mentioned wanted to begin in Spain only. That is fine, and the same appointment covers the rest of the EU when they expand.
Marketplaces check this too. Amazon and other platforms ask non-EU cosmetics sellers for Responsible Person details before listings go live. If you plan to sell through Amazon, our guide on selling on Amazon in the EU walks through the other documents they ask for.
Why this is getting stricter
From 9 December 2026 the new EU Product Liability Directive applies. Under it, a court may presume a product is defective if a company fails to disclose relevant documents. We explain this in our article on the EU Product Liability Directive, and in our piece on suppliers that never send a technical file.
For cosmetics, the PIF is that documentation. A Responsible Person that accepts products without a proper file carries a risk it can no longer absorb. Expect every serious provider to be stricter about the file from now on.
Your checklist before you contact a Responsible Person
- Get a Cosmetic Product Safety Report from a qualified safety assessor for each product.
- Put together the rest of the PIF: product description, manufacturing method, GMP statement, proof of claims and animal testing data.
- Check your claims against Regulation (EU) No 655/2013.
- Prepare your label with all Article 19 information, leaving room for the Responsible Person's name and address.
- Appoint the Responsible Person by written mandate and send over the file for review.
- Let the Responsible Person complete the CPNP notification.
- Only then place the product on the market, on your own shop or on a marketplace.
Conclusion
An EU Responsible Person for cosmetics is more than an address. It keeps your Product Information File, notifies your product in the CPNP and answers to the authorities, so it will only register a product once the safety report and the rest of the file are in order. Start with the CPSR, finish with the CPNP.
We act as EU Responsible Person for cosmetics brands from outside the EU, for an unlimited number of products in one annual service. View the service and send us your file.
Sources
- Regulation (EC) No 1223/2009 on cosmetic products, consolidated version, Articles 4, 5, 8, 10, 11, 13, 19 and 23 and Annex I. EUR-Lex.
- Commission Regulation (EU) No 655/2013 laying down common criteria for the justification of claims used in relation to cosmetic products. EUR-Lex.
- Directive (EU) 2024/2853 on liability for defective products, applicable from 9 December 2026. EUR-Lex.
