Responsible Person for Cosmetics Explained: Do You Need One?

Who needs a Responsible Person for cosmetics?

Every cosmetic placed on the EU market needs one. A seller based outside the EU needs an EU Responsible Person, and Great Britain needs a UK one.

Article 4(1) allows on the EU market only a cosmetic with a Responsible Person designated within the EU. A business established in the EU can hold the role itself. Under Article 4(3), the manufacturer established in the EU is the Responsible Person for a cosmetic made there. Under Article 4(5), each importer is the Responsible Person for the product it places on the market. The importer may designate an EU person by written mandate.

Great Britain has its own rule, which asks for a Responsible Person established in the UK. The guide to the Article 4 obligations covers the duties in detail. This guide covers the buyer's decision: whether to hold the role or appoint someone, and what an appointment costs. The short answer is also in the FAQ on whether you need a Responsible Person.

What does a Responsible Person for cosmetics carry?

The Responsible Person carries the product's legal duties, among them the safety report, the PIF, the notification and the name and address on the label.

Article 10(1) has the Responsible Person see that a safety assessment and a CPSR exist before the product is placed on the market. Article 11 has it keep the PIF for ten years after the last batch. Article 13(1) has it notify the product to the Commission electronically, through the CPNP, before placing it on the market. Article 19(1)(a) puts its name and address on the container and packaging.

The duties apply product by product. A business established in the EU can hold the role itself. Holding the role yourself means doing all of this in house. Appointing one means the appointed person's name and address go on every label, so the choice is partly a branding and logistics decision. The consequences of having none are covered in the guide to Responsible Person penalties.

What is the Eldris Responsible Person service?

It is a separate Eldris service, not part of the per-formula fee. While the plan runs, the EU label carries EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia.

EldrisAi OÜ is the legal entity named on the EU label, and it appears there only while the monthly plan runs. One appointment per country covers every product type, so adding a product type does not mean a new appointment. Eldris prices the role per market. Great Britain is a separate UK appointment at the same market fee, and the same monthly plan covers the UK appointment and the EU one.

When Eldris holds the role, it files the EU notification only as the EU Responsible Person. That happens only when the filing is ordered, and the per-CPSR notification fee applies. The documents side is the CPNP notification and CPSR service, which is a different service from the role. A seller who already holds safety reports can appoint Eldris and order the filing.

What does the Responsible Person service cost?

It is priced per market you choose, then on one monthly plan by number of SKUs. The per-market fee and the plan are on the pricing page.

The per-market fee is paid once for each market you choose, so a brand selling in several markets pays the market fee for each. A discount applies to the market fees only, not to the monthly plan, and it grows with the number of markets. The monthly plan is set by the number of SKUs, and one plan covers the EU and UK appointments. The label carries Eldris's details only while the plan runs.

The EU notification is a separate line, charged per CPSR and not per country. It applies only when Eldris is the EU Responsible Person and the filing is ordered. The cosmetics service has no monthly fee. The CPSR and PIF are paid once. Only the Responsible Person service runs on a monthly plan. Laboratory tests are not in either price.

What happens when the appointment ends?

Cancelling takes effect 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 monthly plan can be cancelled at any time. Plan for the end of the billing period, because the appointment ends then. From then on Eldris is no longer your Responsible Person. Article 19(1)(a) puts the Responsible Person's name and address on the container and packaging. The labels therefore need the next Responsible Person's details before the Eldris details come off. Check every marketplace listing as well as the packaging. A brand established in the EU can take the role itself under Article 4. Otherwise it appoints another EU Responsible Person.

Cancelling concerns the Responsible Person service alone. The CPSR and PIF are paid once, and there is no monthly fee for the cosmetics service. A seller who also sells in Great Britain should note that the UK appointment is a separate appointment. It sits under the same monthly plan.

Frequently asked questions

Can I stay my own Responsible Person?

Yes, if your business is established in the EU. A business established in the EU can hold the role itself. A seller based outside the EU needs an EU Responsible Person. Holding the role yourself means keeping the PIF for ten years after the last batch and filing the notification yourself.

Is the Responsible Person included in the CPSR fee?

No. The Responsible Person is a separate Eldris service. The per-formula fee includes the signed CPSR and the PIF for one formula. It does not cover laboratory tests, the Responsible Person or the Great Britain appointment. One appointment per country covers every product type. The fees for the role are on the pricing page.

Is the EU notification part of the Responsible Person fee?

No. The notification is its own line, charged per CPSR and not per country. Eldris files it only as your EU Responsible Person, and only when the filing is ordered. If you are your own Responsible Person, you file it yourself. The same volume discount as the formula fee applies to it.

Does Great Britain need a separate Responsible Person?

Yes. Under Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, Great Britain needs a UK Responsible Person. Eldris can take that role as a separate appointment at the same market fee as the EU one, under the same monthly plan.

Is the cosmetics service itself monthly?

No. The CPSR and PIF are paid once, with no subscription and no monthly fee for this service. Only the Responsible Person service, if you choose it, runs on a monthly plan. You can cancel it at any time, effective at the end of the billing period.

Who is the Responsible Person for an imported cosmetic?

Each importer is the Responsible Person for each product it places on the market, under Article 4(5). The importer may designate a person established in the EU by written mandate. Eldris can be that person as a separate service, priced per market. One appointment per country covers every product type.

Which name and address appear on the label when Eldris is the EU Responsible Person?

While the monthly plan runs, the EU label carries EldrisAi OÜ, Ruunaoja tn 3, 11415 Tallinn, Estonia. Article 19(1)(a) requires the Responsible Person's name and address on the container and packaging. When the appointment ends, Eldris's details must come off labels and listings within 30 days.