EU cosmetics · Reg (EC) 1223/2009
Do you need an EU Responsible Person?
Every cosmetic placed on the EU market must have a designated Responsible Person established in the Union. Pick your role and tell us where you are established — find out who the Responsible Person is for your products, and what is always required.
The rule, in one line
Under Regulation (EC) 1223/2009 Article 4, only cosmetic products with a designated Responsible Person established in the Union may be placed on the EU market. An EU manufacturer is the RP for its own products; an importer is the RP for what it imports; a distributor becomes the RP if it sells under its own name/trademark or modifies the product; and a manufacturer outside the EU must appoint an EU-established RP by written mandate. The RP must also notify the product through the CPNP (Article 13) before it is sold.
Official sources: Regulation (EC) 1223/2009 · European Commission — consolidated text · EUR-Lex summary
Responsible Person verdict
You must appoint an EU Responsible Person
You cannot place the product on the EU market without a Responsible Person established in the Union. Appoint one by written mandate (they must accept in writing) before you sell.
Always required, regardless of role
- A Responsible Person established in the EU/EEA must be designated before the product is placed on the market.
- The product must be notified through the Cosmetic Products Notification Portal (CPNP) under Article 13 before sale.
Per-brand memo
Responsible Person memo (PDF) · €29
A print-ready pack for your brand: who the Responsible Person is for your set-up, what that means, the always-required RP + CPNP obligations, and the source citations — for your compliance file.
This is guidance, not legal advice. The export restates Article 4 for your inputs; it does not assess the RP's substantive duties.
What this tool is — and isn't
This checker resolves who the Responsible Person is under Regulation (EC) 1223/2009 Article 4 from the role you describe. It is an estimate and orientation, not legal advice, and it does not assess the RP's substantive duties (product information file, safety assessment, labelling) or borderline supply-chain set-ups. Verify against the linked official sources.
How the determination works
1. Your role
Whether you are the Responsible Person depends on how you act: manufacturer, importer, distributor, or another actor placing the product on the EU market.
2. Where you are established
An EU-established manufacturer is the RP for its products. A manufacturer outside the EU must appoint an EU-established RP by written mandate. An importer is the RP for the products it imports.
3. Distributor nuance + always-on duties
A distributor becomes the RP only if it sells under its own name/trademark or modifies the product. In every case a designated EU RP and CPNP notification are required before the product is sold.
Frequently asked questions
- Does every cosmetic need a Responsible Person?
- Yes. Under Article 4 of Regulation (EC) 1223/2009, only cosmetics with a designated Responsible Person established in the Union may be placed on the EU market.
- I manufacture outside the EU — who is the RP?
- You must appoint an EU-established Responsible Person by written mandate (they accept in writing). Often this is the importer or a specialist RP service.
- I import cosmetics into the EU — am I the RP?
- Yes. The importer is the Responsible Person for the specific products it places on the EU market, unless it designates a mandated RP established in the Union.
- I only resell — am I the RP?
- Not usually. A distributor becomes the Responsible Person only if it sells under its own name/trademark or modifies the product affecting compliance. Otherwise the existing RP stays responsible and you have distributor duties.
- What is CPNP?
- The Cosmetic Products Notification Portal. The Responsible Person must notify product information through CPNP (Article 13) before the cosmetic is placed on the market.
- Is this legal advice?
- No. This tool resolves who the Responsible Person is from your role. It is orientation, not legal advice, and does not assess the RP's substantive duties. Verify against the linked official sources.