Switching CPSR Provider When You Already Have Safety Reports

What can move to Eldris from another provider?

Two things can move to Eldris: the Responsible Person appointment and the notification filing.

A brand appoints Eldris as its EU Responsible Person, orders the notification filing, and Eldris files the EU notification. Whether Eldris takes over or re-signs a CPSR or PIF written by another provider is not stated here. The Regulation explains why these two matter. Under Article 4(1), only a cosmetic with a Responsible Person designated within the EU may be placed on the EU market. Under Article 13, the Responsible Person notifies the product to the Commission electronically, through the Commission's CPNP, before placing it on the market. A seller based outside the EU needs an EU Responsible Person, and Great Britain needs a UK one, while a business established in the EU can hold the role itself. Eldris offers the role as a separate service, with a one-off fee for each market and then a monthly plan. One appointment per country covers every product type.

How does a brand move from another provider?

A brand moves in a short sequence: choose the markets, appoint Eldris for each, order the filing, then update the label.

A brand that already has safety reports follows the same sequence. Choose the markets first, because each market is a separate appointment. For Great Britain, Eldris can be the UK Responsible Person as a separate appointment at the same market fee, covered by the same monthly plan. GOV.UK guidance states that a UK Responsible Person needs a UK established address. To order a new CPSR and PIF, pay first, then upload your documents in your Eldris portal, where Eldris tells you what is still missing. If the safety assessor needs more, the question appears there, and the 5–10 working days start again from the day you answer. The CPSR and PIF are delivered through the cosmetics compliance service 5–10 working days after complete documents. The EU notification filing follows the appointment, because Eldris files it only as your EU Responsible Person.

What changes on the label?

The label item a change of Responsible Person touches is the name or registered name and address of the Responsible Person.

Article 19(1)(a) of the same Regulation requires the container and packaging to carry it. While Eldris is your EU Responsible Person and your monthly plan runs, the label carries EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia. The other items Article 19 names describe the product, not the provider. They include the nominal content by weight or volume and the ingredients list. They also include the date of minimum durability or, where that rule allows, the period after opening, and the batch number of manufacture or a reference identifying the product. A change of Responsible Person leaves them as they are. The ingredients list may be given on the packaging alone. The Tallinn address is for the EU label only. The Great Britain appointment is separate, and no Great Britain label address is stated here.

What does the brand keep and decide?

The brand keeps its formula, its product range and its decisions about testing.

Eldris does not carry out, arrange or recommend laboratory tests, so stability, challenge, SPF and microbiology tests stay with a testing laboratory, which sets its own price. The brand decides which markets to enter, since each market is a separate appointment. The brand also keeps the choice to leave. The Responsible Person plan can be cancelled at any time, effective at the end of the billing period. The appointment then ends, and Eldris's details must come off labels and listings within 30 days. The cosmetics fees are paid once, with no monthly fee for that service, and only the Responsible Person service runs on a monthly plan. Under Article 11, the Responsible Person keeps the PIF for ten years after the last batch. The PIF holds the CPSR, the manufacturing method and a GMP statement, and data on any animal testing.

What does a switch cost?

Eldris's fees for a switch are shown on the pricing page.

They include the Responsible Person's per-market fee and monthly plan, the notification fee, and the per-formula fee if the brand orders a new CPSR and PIF from Eldris. The notification fee is charged per CPSR, and only when Eldris is your EU Responsible Person and the filing is ordered. Great Britain's UK Responsible Person and UK notification are priced separately from the EU appointment. Laboratory tests are paid to the laboratory, which sets the price. The cosmetics fees are paid once, with no monthly fee for that service, so a new CPSR order adds no subscription. The pricing page holds the figures, so this page prints none. The post on what a CPSR and PIF contain lists what a new per-formula order delivers, and the FAQ entry on switching provider holds the short answer.

Frequently asked questions

Who files the notification after I switch?

The Responsible Person files it. Eldris files the EU notification only as your EU Responsible Person, when you have ordered the filing, and the notification fee is charged per CPSR. Otherwise your own Responsible Person files it. In the EU the filing goes through the Commission's notification portal. The filing is a separate line from the CPSR and PIF.

Does one appointment cover all my products?

One appointment per country covers every product type. The EU notification is charged per formula, not per country. A seller based outside the EU needs an EU Responsible Person, and Great Britain needs a UK one. That holds for every product the brand sells in that country.

Do I need a UK Responsible Person as well?

Great Britain needs a Responsible Person established in the UK. Eldris can be the UK Responsible Person as a separate appointment at the same market fee, covered by the same monthly plan. A UK Responsible Person needs a UK established address, and the UK notification is a separate line, priced separately.

Can I cancel the Responsible Person plan later?

Yes, at any time, effective at the end of the billing period. The appointment then ends, and Eldris's details must come off labels and listings within 30 days. Only the Responsible Person service runs on a monthly plan, and the plan covers that service alone.

Is the cosmetics service billed monthly?

No. The cosmetics fees are paid once, with no monthly fee for that service. Only the Responsible Person service, if you choose it, runs on a monthly plan, which is set by the number of SKUs. If you order only a CPSR and PIF, you pay the per-formula fee once and nothing recurs for that service.

How is a new CPSR ordered after a switch?

A new CPSR and PIF from Eldris is priced per formula and delivered 5–10 working days after complete documents. You pay first, then upload in your Eldris portal. The Responsible Person is a separate Eldris service, and the EU notification is a separate line.

Can I stay my own Responsible Person if I am established in the EU?

Yes. A business established in the EU can hold the role itself. For a cosmetic made in the EU, the manufacturer established in the EU is the Responsible Person (Article 4(3)). For an imported cosmetic, each importer is the Responsible Person and may designate an EU person by written mandate (Article 4(5)).