What the Cosmetic Products Regulation requires
Regulation (EC) No 1223/2009 is the governing legislation for cosmetics in the EU. It requires that:
- A Responsible Person established in the EU is designated for every product
- The product is notified through the CPNP before being placed on the market
- A Product Information File is maintained and kept accessible for ten years
- A Cosmetic Product Safety Report has been prepared by a qualified safety assessor
- Labelling carries the responsible person’s details, ingredient list, batch number and shelf life
- Claims are substantiated and comply with the Common Criteria
The Responsible Person is not an administrative formality. They carry legal accountability for the product’s compliance within the EU, which is why the role has to be formally mandated rather than borrowed.
Who needs this
- Non-EU skincare and cosmetics brands selling into the European market
- Amazon, Shopify and Etsy sellers listing cosmetics, skincare or personal care products in the EU
- US, UK and Korean beauty brands expanding into Europe
- Private-label and white-label brands treated as the manufacturer in the EU
- Wellness brands whose range includes topical products
What we do
- Act as your named EU Responsible Person under Regulation 1223/2009
- Provide an EU address for your labelling and packaging
- Handle your CPNP notification and keep it current as formulations change
- Review and hold your Product Information File and safety documentation
- Check your labelling and claims against the Common Criteria before you print
- Respond to authority inquiries and manage corrective action
- Retain documentation for ten years
How it works
- Send us your product range — formulations, existing safety reports and current labelling.
- We review your documentation and tell you what is missing before it becomes a problem.
- Appointment and notification — appointed within 24 hours, and we handle the CPNP submission.
- Ongoing coverage — we hold your file, keep notifications current and handle authority contact.
Common mistakes we see
- Assuming a distributor can act as Responsible Person. The role must be formally mandated in writing.
- Selling before CPNP notification. Notification must be completed before the product is placed on the market.
- An incomplete Product Information File. A safety report alone is not a PIF.
- Non-compliant claims. Terms suggesting a medical effect can reclassify your product entirely.
- Assuming the EU covers the UK. Great Britain has its own regime and portal.
Frequently asked questions
Do I need an EU Responsible Person for cosmetics?
Yes. Regulation (EC) No 1223/2009 requires every cosmetic product placed on the EU market to have a designated Responsible Person established in the Union. Without one the product cannot legally be sold.
What does the cosmetics Responsible Person actually do?
They are legally accountable for the product’s compliance in the EU. They hold the Product Information File, ensure the CPNP notification is made, respond to authority inquiries, and act if a product needs to be withdrawn.
What is CPNP notification?
Before a cosmetic product is placed on the EU market it must be notified through the Cosmetic Products Notification Portal. The notification covers the formulation, the responsible person and the product presentation, and must be kept current.
What is a Product Information File?
The PIF is the dossier held for each product: description, Cosmetic Product Safety Report, manufacturing method, evidence of claimed effects and safety data. It must be kept accessible for ten years.
Do I need a separate Responsible Person for the UK?
Yes. Great Britain has its own regime with a UK Responsible Person and notification via the SCPN portal. An EU appointment does not cover the UK.
How quickly can you be appointed?
Within 24 hours of your application.
Get your cosmetics EU-compliant
Responsible Person appointed within 24 hours.
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