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What is an EU Cosmetics Responsible Person (RP), and when do you need one?
I'm a cosmetics manufacturer based outside the EU. I've heard about Responsible Person requirements under EU Cosmetics Regulation but I'm not sure if they apply to my situation. Can you explain what an EU Cosmetics Responsible Person is and when it's mandatory?
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Asked by Lo H. Khamis
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Lo H. Khamis, Regulatory Experts
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## What is an EU Cosmetics Responsible Person (RP)?
An **EU Cosmetics Responsible Person (RP)** is a legal entity established within the European Union that acts as the regulatory interface for manufacturers not established in the EU. According to Regulation (EC) No 1223/2009 on cosmetic products, the RP represents the manufacturer for regulatory compliance matters related to placing cosmetic products on the EU market.
### When Do You Need an EU Cosmetics RP?
You typically need an EU Cosmetics RP if:
1. **Your legal manufacturer address is outside the EU/EEA** - This includes manufacturers based in the United States, Asia, or any other country outside the EU/EEA. Regulation 1223/2009 treats all non-EU manufacturers as requiring an RP.
2. **You want to place cosmetic products on the EU/EEA market** - The RP requirement applies to:
- All cosmetic products (makeup, skincare, haircare, perfumes, etc.)
- Products placed on the market in any EU member state
- Both finished products and products sold to consumers
### Legal Basis
Article 4 of Regulation (EC) No 1223/2009 explicitly states that **cosmetic products may only be placed on the market if a responsible person is designated within the Community**. This is not optional—it's a mandatory requirement for market access.
### Key Distinction from Medical Devices
Unlike medical devices (which use "Authorized Representative"), cosmetics use the term **"Responsible Person"**. The RP assumes legal responsibility for the cosmetic products and must be established in the EU.
### Practical Takeaway
If you ship cosmetic products into the EU under your non-EU manufacturer name, you **must** have an EU Cosmetics RP. The requirement is independent of whether you have other certifications—the RP is a separate regulatory obligation that must be met.
**Important Note**: The RP must be established in an EU member state. They cannot be based in the UK (post-Brexit), Switzerland, or other non-EU countries.
### Next Steps
1. Verify your manufacturer location and distribution model
2. Confirm your product classification (cosmetic vs. medical device vs. biocidal)
3. Engage a qualified EU Cosmetics RP provider before placing products on the market
4. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Get quotes from multiple providers to find the best fit
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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:
- [Regulation (EC) No 1223/2009 on cosmetic products](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)
- [European Commission - Cosmetics overview](https://ec.europa.eu/single-market-economy/sectors/cosmetics_en)