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UK Responsible Person for cosmetics: who it can be and what they do

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If you sell cosmetics into Great Britain from outside the UK, a business established in the UK must act as each product’s responsible person. That can be a UK importer, a UK manufacturer, or a UK business you appoint by written mandate. Northern Ireland follows EU rules, so its responsible person must be in Northern Ireland or the EU.

The rules come from the UK version of the Cosmetics Regulation, explained in OPSS guidance. For how the role works across the EU and UK in general, see our EU and UK Responsible Person service page; everything below is specific to cosmetics.

Who can be your responsible person: GB and Northern Ireland side by side

GB applies the UK version of Regulation (EC) No 1223/2009. Northern Ireland applies the EU version under the Windsor Framework.

Great Britain (England, Scotland, Wales) Northern Ireland
Where the responsible person must be established The UK Northern Ireland or the EU. A GB-based responsible person is not accepted.
Who it can be A UK manufacturer, a UK importer, or a UK-established person appointed by written mandate who accepts in writing A manufacturer or importer, or a third party appointed by written mandate, based in NI or the EU
Where each product is notified The UK SCPN service The EU portal (CPNP). A product also sold in GB needs a separate SCPN notification.
Product information file In English, at the address notified, kept for ten years after the last batch At the address notified, kept for ten years after the last batch
Country of origin on imports Required, including for goods from the EU. “Made in the EU” is not accepted. Until 31 December 2027, a label that meets the EU name, address and country of origin rules is accepted instead. Required, including for goods from GB, which can state “Made in UK”

For a brand with no UK company, note that the GB guidance defines an importer as a business established in the UK. If no one in your supply chain is established in the UK, the route left is a written mandate to a UK-established person who accepts it in writing. An EU responsible person cannot fill the GB role unless it is also established in the UK, and a GB-based one cannot fill the NI role.

For the same question across other product types, such as electricals or medical devices, see UK Responsible Person requirements by product type.

What the responsible person must do

Under the GB guidance the responsible person must:

  • make sure a safety assessment is completed before the product is placed on the GB market;
  • hold the product information file and make it readily available to the authorities at the address notified;
  • notify every product through SCPN before it is first supplied in GB, and update the notification straight away when anything changes;
  • take corrective action, withdraw or recall a product they believe does not comply, in proportion to the problem;
  • tell the authorities immediately about a product that presents a risk;
  • make sure claims about the product are truthful and backed by evidence;
  • report serious undesirable effects to the Secretary of State on the UK form. The UK reads “without delay” as within 30 calendar days of anyone in the company hearing of a possible case.

What goes in the product information file

The GB guidance lists five parts of the product information file (PIF):

  1. A description of the product.
  2. The Cosmetic Product Safety Report (CPSR), signed by a qualified safety assessor. Part A holds the safety information, such as composition, stability, microbial quality, impurities, exposure and the toxicological profile. Part B holds the assessor’s conclusion, the warnings needed on the label, their reasoning, and their signature and date.
  3. The method of manufacture and information on good manufacturing practice.
  4. Proof of the effect claimed for the product.
  5. Data on any animal testing.

The safety assessor should hold a qualification in pharmacy, toxicology, medicine or a similar discipline, or a recognised equivalent. Keep the PIF in English, up to date, and for ten years after the last batch is placed on the market.

SCPN notification, step by step

SCPN (Submit Cosmetic Product Notifications) is run by the Office for Product Safety and Standards. Every cosmetic available to consumers in Great Britain must be notified on it before it is first supplied.

  1. Get access. The responsible person signs in with a GOV.UK One Login. Anyone with an older SCPN account uses the same email address for their One Login.
  2. Gather the core details. The product name and category, the responsible person’s name, the address where the PIF is kept, and a named person to contact in an emergency. The SCPN page describes this as a contact for the National Poisons Information Service or Trading Standards.
  3. Prepare the formulation. Give the frame formulation, which lets doctors treat someone quickly if something goes wrong. Name any category 1A or 1B CMR substances with their CAS or EC numbers.
  4. Add the label. Upload the original labelling and, where it is legible, a photo of the packaging.
  5. Check for nanomaterials. A product containing nanomaterials, other than those used as colourants, preservatives or UV filters, must be notified at least six months before it goes on sale, with their identity and reasonably foreseeable exposure.
  6. Submit, then keep it current. Notify before the first unit is supplied in GB, and update the notification as soon as any of the information changes.

If the same product is also sold in Northern Ireland, it needs a notification to the EU through CPNP as well, made by the NI or EU responsible person.

What the label must show

These particulars must appear clearly and indelibly on the container and the outer packaging, unless an exemption applies. The ingredients list can go on the outer packaging alone:

  • the responsible person’s name and address (an abbreviation is fine if they can still be identified);
  • the country of origin for imported products;
  • the nominal content by weight or volume, with exemptions for free samples, packs under 5g or 5ml, single applications and some multipacks;
  • a “best used before the end of” date or the hourglass symbol for products that keep for 30 months or less, or a period after opening symbol for longer-lasting products;
  • warnings and precautions for use, in English;
  • a batch number or other reference to identify the batch;
  • the product’s function in English, unless it is obvious from the presentation;
  • an ingredients list headed “ingredients”, using the common ingredient names in descending order of weight, with fragrance shown as “parfum” or “aroma”, certain fragrance ingredients declared above 0.001% in leave-on or 0.01% in rinse-off products, and nanomaterials marked “(nano)”.

Where there is no room for all of it, the information can go in an enclosed leaflet, flagged on the pack with the hand and book symbol. Until 31 December 2027, GB treats the name, address and country of origin rules as met by a label that follows the EU rules, such as one showing an EU or EEA responsible person’s name and address. That eases the label only: the product still needs a responsible person established in the UK.

Worked example: a non-UK moisturiser on Amazon.co.uk

Willowmere Skincare is a fictional brand based in Canada with no UK company. It wants to sell one face moisturiser on Amazon.co.uk, shipped into a UK fulfilment centre. It works through the official steps in this order:

  1. It has no UK establishment and no UK importer, so it appoints a UK-established business as responsible person by written mandate, and gets the acceptance in writing.
  2. It commissions a CPSR from a qualified safety assessor and builds the PIF in English at the responsible person’s address.
  3. It reprints the carton and jar with the UK responsible person’s name and address, “Made in Canada”, the nominal content, a period after opening symbol (the cream keeps for more than 30 months), a batch code, English warnings and the ingredients list.
  4. The responsible person notifies the moisturiser on SCPN before the first unit ships.
  5. Willowmere decides not to sell into Northern Ireland for now. If it does later, it will need an NI or EU responsible person and a CPNP notification as well.

Before the first cosmetic ships to GB: seven checks

  • Do you, or anyone in your supply chain, have a business established in the UK? If not, who will you appoint by written mandate, and have they accepted in writing?
  • Is there a signed CPSR for each product, and is the PIF complete, in English and at the responsible person’s address?
  • Has each product been notified on SCPN, with the label image and frame formulation?
  • Does any formula contain nanomaterials other than colourants, preservatives or UV filters, and if so was it notified six months ahead?
  • Does the pack carry every label particular listed above?
  • Do you know who reports a serious undesirable effect, and how fast?
  • Are you selling into Northern Ireland too? If so, have you arranged an NI or EU responsible person and a CPNP notification?

Where to go from here

Our Responsible Person plans and prices page sets out the UK package. It does not list cosmetics, SCPN notification or PIF work, and we review your product files before we agree to act, so tell us what you sell before you assume it fits. Use our contact form with your brand, product categories and markets, and we will say what we can and cannot cover. General questions are answered in our Responsible Person and GPSR FAQs.

Frequently asked questions

My labels show an EU responsible person. Is that enough for GB until 2027?

For the label, yes: until 31 December 2027 GB accepts EU or EEA responsible person details. For the product, no: it still needs a responsible person established in the UK.

Does a GB-based responsible person work for cosmetics sold in Northern Ireland?

No, unless they are based in Northern Ireland. The NI guidance says responsible persons cannot be based in Great Britain; they must be in Northern Ireland or the EU.

Is Amazon my responsible person if I use its fulfilment service?

The GB guidance names the manufacturer, the importer, a person appointed by written mandate and, in some cases, a distributor. It does not name a marketplace or fulfilment service, so do not assume Amazon fills the role.

I already notified my product on CPNP. Do I still need SCPN?

Yes, for Great Britain. CPNP covers the EU and Northern Ireland; GB needs its own notification through SCPN before the product is supplied there.

Sources

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