UK Responsible Person requirements: who needs one

A UK Responsible Person is the UK-based business that carries legal duties for a product sold in Great Britain. There isn’t one role for every product: cosmetics need a UK-established responsible person, medical devices from overseas makers need a UK Responsible Person (UKRP), and UKCA or CE-marked goods need a UK importer or authorised representative.

This guide sets out who needs what, product type by product type, for sellers based outside the UK, including Amazon sellers shipping into Great Britain (England, Scotland and Wales) and Northern Ireland.

UK Responsible Person requirements by product type

Product type	Who the UK party is	Main duties
Cosmetics (GB)	A “responsible person” established in the UK	Notify each product through the UK’s Submit cosmetic product notifications (SCPN) service before it goes on sale in GB
Medical devices (GB)	A UK Responsible Person (UKRP), appointed by a manufacturer based outside the UK	Register the devices with the MHRA, keep technical documentation and the declaration of conformity available, cooperate with the MHRA
UKCA or CE-marked goods, such as toys and electrical products (GB)	A UK-established importer or authorised representative	The importer’s name and postal address normally go on the product or its packaging
Products covered by the EU GPSR (Northern Ireland)	A responsible economic operator established in Northern Ireland or the EU	Make sure compliance tasks are done and tell authorities about safety incidents

Cosmetics: the responsible person

Under the UK version of the Cosmetics Regulation, a cosmetic product can’t be placed on the market in Great Britain unless there is a responsible person established in the UK. Who that is depends on how the product reaches the UK:

If you import it: any importer placing a cosmetic product on the market is its responsible person, unless it designates someone else in writing.
By written mandate: the importer, or a UK-established manufacturer, can designate another UK-established person as responsible person by written mandate. The designation takes effect when that person accepts in writing. A manufacturer outside the UK must designate one this way for cosmetics made in the UK.
If a distributor sells it under its own name or trade mark, or changes it in a way that could affect compliance, the distributor becomes the responsible person.

Before a new cosmetic product goes on sale in GB, it must be notified through the SCPN service. Northern Ireland has a separate process. Our guide to the UK responsible person for cosmetics covers SCPN notification, the product information file and labelling in detail.

Medical devices: the UKRP

The MHRA’s guidance says manufacturers based outside the UK must appoint a UK Responsible Person to place a device on the Great Britain market. Importers and distributors don’t need to appoint one. The UKRP’s tasks include:

registering the manufacturer’s devices with the MHRA before they go on the GB market
keeping the technical documentation and declaration of conformity available for the MHRA to inspect
cooperating with the MHRA on any preventive or corrective action
telling the manufacturer straight away about complaints and reports of suspected incidents

Where a device carries the UKCA mark, the UKRP’s name and address go on the labelling, the outer packaging or the instructions for use. For Northern Ireland, the MHRA says GB-based manufacturers must appoint an authorised representative in the EU or Northern Ireland.

UKCA and CE-marked goods: importer or authorised representative

Great Britain still recognises CE marking for many product types, with no end date stated. Medical devices, construction products and some other sectors have their own rules. For UKCA or CE goods sold in GB, importers and authorised representatives must be established in the UK, and the importer’s name and postal address normally appear on the product or its packaging. For some products imported from the EEA before 11pm on 31 December 2027, the importer’s details can be set out elsewhere instead of on the product itself.

General products with no UKCA or CE marking (GB)

This is the grey area. Great Britain stays under the UK General Product Safety Regulations 2005, not the EU GPSR. We haven’t found official guidance that settles whether GB requires a named UK responsible person for general consumer products outside the UKCA and CE regimes, so be wary of anyone who states it as fact either way. The Product Regulation and Metrology Act 2025 lets the government update UK product rules, and a consultation on a new framework closed on 23 June 2026. We haven’t seen any dates or content for new GB rules confirmed yet.

Northern Ireland: the EU rules apply

The EU General Product Safety Regulation (GPSR) applies in Northern Ireland but not in Great Britain. For products it covers to be placed on the Northern Ireland market, there must be a responsible economic operator established in Northern Ireland or the EU. If you are a GB small business deciding whether to ship to Northern Ireland at all, our guide to GPSR for UK small businesses compares three routes: GB only, GB plus Northern Ireland, and GB plus the EU.

What makes you a UK Responsible Person?

You become one in one of three ways, depending on the product:

By your role in the supply chain. A UK importer of cosmetics is the responsible person unless it designates someone else in writing. For UKCA and CE goods, the UK importer takes on importer duties, including putting its details on the product.
By written appointment. A UK-established person or business is appointed in writing: for cosmetics, by the importer (or by the manufacturer, for products made in the UK); for medical devices, a UKRP appointed by a manufacturer outside the UK; for UKCA and CE goods, an authorised representative appointed by the manufacturer.
By selling under your own brand. For cosmetics, a distributor that sells a product under its own name or trade mark becomes its responsible person.

For these GB regimes the person or business has to be established in the UK. If you’re a seller based outside the UK, that means appointing someone, or setting up a UK importer, rather than doing it yourself.

Does an EU Responsible Person cover Great Britain?

Not for the GB regimes above. In the EU, a product can’t be placed on the market unless an economic operator established in the EU is responsible for it (GPSR Article 16(1)). That EU operator doesn’t meet the GB requirements for cosmetics, medical devices or UKCA and CE goods, which all need a UK-established party. If you sell cosmetics, medical devices or UKCA or CE goods in both markets, you need cover in each.

Northern Ireland is the exception that works the other way: because the GPSR applies there, the responsible economic operator for Northern Ireland can be established in the EU.

A checklist for sellers shipping into the UK

Sort your products by regime. Cosmetic, medical device, UKCA or CE-marked (toys, electrical, radio equipment and so on), or a general consumer product.
Cosmetics: agree who the UK responsible person is (your UK importer, or a UK-established business the importer designates in writing) and notify each product on SCPN before it goes on sale in GB.
Medical devices: appoint a UKRP and make sure your devices are registered with the MHRA before they reach the GB market.
UKCA and CE goods: name a UK-established importer or authorised representative, and check the importer’s name and postal address are on the product or packaging.
Northern Ireland: check you have a responsible economic operator in Northern Ireland or the EU for products the GPSR covers.
Keep your paperwork ready. Whoever acts for you will need your technical documentation, and a declaration of conformity where the product’s rules require one. A template helps you start, but it doesn’t replace a real risk analysis and testing where needed.
Watch for UK rule changes under the Product Regulation and Metrology Act 2025.

Getting a UK Responsible Person

If you need a UK address on your labels and listings, our UK Responsible Person service provides one, holds and reviews your technical file, and handles requests from authorities. For UKCA and CE goods you still need a UK importer or authorised representative, so check with us which role fits your products. You can compare the UK, EU and EU + UK Responsible Person plans, or start your technical file with a compliance template pack for your product category. Cosmetics notifications and medical devices have their own rules, so if you sell either, read our Responsible Person FAQs or ask us before you sign up.

Frequently asked questions

What is a UKRP?

UKRP is short for UK Responsible Person, the term used for medical devices. A manufacturer based outside the UK must appoint one to place devices on the Great Britain market. The UKRP registers the devices with the MHRA and cooperates with it on any corrective action.

Is a UK Responsible Person the same as an importer?

Sometimes. For cosmetics, any importer placing a product on the market is its responsible person, unless it designates someone else in writing. For medical devices, the UKRP is appointed by the manufacturer, and importers don’t need to appoint one.

Do I need a UK Responsible Person to sell on Amazon UK?

The legal answer depends on your product: cosmetics, medical devices and UKCA or CE goods all need a UK-established party, as set out above. Check Amazon’s own requirements in Seller Central too.

Can my EU Responsible Person cover Northern Ireland?

For products covered by the GPSR, yes: the responsible economic operator for Northern Ireland can be established in Northern Ireland or the EU. It doesn’t cover Great Britain.

Does the GPSR apply in the UK?

Only in Northern Ireland. Great Britain stays under the UK General Product Safety Regulations 2005.

Sources

This guide is general information, not legal advice. Checked 17 October 2026.

What is a UK Responsible Person? Requirements by product type