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What does a UK Responsible Person actually do (and what they don't do)?
I need to understand the exact scope of UK RP responsibilities. What are they legally required to do versus what they might offer as additional services? Also, what are common misconceptions about their role?
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Asked by Lo H. Khamis
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Lo H. Khamis, Regulatory Experts
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## What Does a UK Responsible Person Actually Do?
Think of the UK RP as your **UK compliance interface**, not your commercial distributor. Understanding the distinction between their regulatory responsibilities and what they don't do is critical for setting proper expectations.
### Common UK RP Responsibilities
According to UK MDR 2002, the UK RP has several key responsibilities:
#### 1. **Documentation Management**
- **Holding or ensuring access to key compliance artifacts** - The UK RP must either:
- Physically hold the technical documentation, OR
- Contractually ensure the manufacturer can provide it to MHRA upon request
- Ensuring technical documentation can be provided to MHRA quickly when requested
- Maintaining documentation in a format accessible to MHRA
#### 2. **Mandate Governance**
- Ensuring the relationship is governed by a **written mandate** with the manufacturer
- The mandate must clearly define scope, responsibilities, and operational procedures
- The mandate must comply with UK MDR 2002 requirements
#### 3. **Vigilance and Safety Reporting**
- Supporting and ensuring required reporting flows to MHRA for:
- **Serious incidents** occurring in the UK
- **Field Safety Corrective Actions (FSCAs)** in the UK
- **Trend reporting** as required
- The UK RP is responsible for ensuring reports are sent to MHRA (not just facilitating)
#### 4. **Regulatory Cooperation**
- Cooperating with MHRA on preventive and corrective actions when needed
- Responding to MHRA inquiries and requests for information
- Maintaining communication channels with regulatory authorities
- Providing information to MHRA upon request
#### 5. **Registration and Compliance**
- Registering devices with MHRA if required
- Maintaining compliance with UK MDR 2002 economic operator obligations
- Ensuring proper device registration and UDI compliance
### What a UK RP Usually Is NOT
#### ❌ Not Automatically Your Importer of Record
The UK RP and importer are **separate legal roles** with distinct obligations under UK MDR 2002. A company can serve as both, but they must:
- Meet both sets of obligations
- Clearly distinguish the roles in their operations
- Register separately for each role if required
#### ❌ Not Your Commercial Seller
Unless you specifically contract them to do so, the UK RP is not your distributor or sales agent. Their role is regulatory, not commercial.
#### ❌ Not Your Quality System Auditor
The UK RP doesn't audit your quality system or manufacturing processes. They rely on your existing certifications and documentation.
#### ❌ Not Your Legal Representative for Commercial Disputes
The UK RP represents you for regulatory matters with MHRA, not for commercial or legal disputes with customers or partners.
### Practical Implications
When selecting a UK RP, ask:
- Do they hold technical files or rely on contractual manufacturer submission?
- What is their vigilance reporting process and response time?
- How do they handle MHRA inquiries and requests?
- What documentation and support do they provide?
- Do they offer additional services (PRRC, device registration support, etc.)?
### Next Steps
1. Evaluate UK RP providers based on their service model and capabilities
2. **[Compare UK Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/uk_rp)** - Review multiple providers to find the right fit for your needs
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*Written by **Lo H. Khamis**, Regulatory Experts. [Connect on LinkedIn](https://www.linkedin.com/in/lo-h-khamis) for regulatory guidance.*
### Official Sources:
- [MHRA - UK Responsible Person Obligations](https://www.gov.uk/government/organisations/medicines-and-healthcare-products-regulatory-agency)