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What does an EU Cosmetics Responsible Person actually do (and what they don't do)?

I need to understand the exact scope of EU Cosmetics 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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## What Does an EU Cosmetics Responsible Person Actually Do? Think of the EU Cosmetics RP as your **EU compliance interface** for cosmetic products. Understanding the distinction between their regulatory responsibilities and what they don't do is critical for setting proper expectations. ### Common EU Cosmetics RP Responsibilities According to Regulation (EC) No 1223/2009, the RP has several key responsibilities: #### 1. **Product Safety and Compliance** - **Ensuring product safety before placing on the market** - The RP must verify that products comply with EU Cosmetics Regulation before they are placed on the market - Ensuring products meet safety requirements and ingredient restrictions - Verifying that products do not contain prohibited substances #### 2. **Product Information File (PIF) Management** - **Maintaining the Product Information File (PIF)** - The RP must maintain the PIF and make it available to competent authorities upon request - The PIF must include safety information, product description, manufacturing method, and evidence of claimed effect - Ensuring PIF is kept up to date and accessible #### 3. **CPNP Notification** - **Submitting CPNP notifications** - The RP must submit notifications to the Cosmetic Products Notification Portal (CPNP) before products can be placed on the market - Ensuring all required information is included in CPNP notifications - Maintaining compliance with CPNP requirements #### 4. **Labeling Compliance** - **Ensuring proper labeling** - The RP must ensure products are properly labeled according to EU Cosmetics Regulation - Verifying that required information (ingredients, warnings, etc.) is present - Ensuring labeling is in appropriate languages #### 5. **Regulatory Cooperation** - **Serving as contact point** - The RP serves as the contact point for competent authorities - Responding to authority inquiries and requests for information - Cooperating with authorities on corrective actions and market surveillance #### 6. **Serious Undesirable Effects (SUE) Reporting** - **Reporting serious undesirable effects** - The RP must report serious undesirable effects to competent authorities - Maintaining records of adverse effects - Coordinating with manufacturers on SUE reporting ### What an EU Cosmetics RP Usually Is NOT #### ❌ Not Your Product Developer The RP doesn't develop or formulate your products. They ensure regulatory compliance of products you've already developed. #### ❌ Not Your Commercial Seller Unless you specifically contract them to do so, the RP is not your distributor or sales agent. Their role is regulatory, not commercial. #### ❌ Not Your Safety Assessor While the RP must ensure safety assessments are in place, they typically don't conduct safety assessments themselves. You'll need a qualified safety assessor (often a separate service). #### ❌ Not Your Quality Control Lab The RP doesn't test your products or conduct quality control. They rely on your existing testing and documentation. ### Practical Implications When selecting an EU Cosmetics RP, ask: - Do they maintain PIFs or rely on manufacturer-provided documentation? - What is their CPNP notification process and turnaround time? - How do they handle SUE reporting and authority inquiries? - What documentation and support do they provide? - Do they offer additional services (safety assessment, labeling review, etc.)? ### Next Steps 1. Evaluate EU Cosmetics RP providers based on their service model and capabilities 2. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Review multiple providers to find the right fit for your needs --- *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 - Article 4, Article 5](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)