Can I change my EU Cosmetics Responsible Person, and what's the process?

## Can I Change My EU Cosmetics Responsible Person? **Yes, you can change your EU Cosmetics RP**, but the process requires coordination. The new RP must be appointed before the previous one is terminated, and you must update CPNP notifications and ensure continuity of regulatory compliance. ### The Legal Framework Regulation (EC) No 1223/2009 allows manufacturers to change their Responsible Person, but the process must ensure continuity of regulatory compliance and proper notification to authorities. ### The Process #### 1. **Appoint New RP First** - Engage and contract with your new RP - Ensure the new RP is ready to take over responsibilities - Complete the written mandate with the new RP #### 2. **Update CPNP Notifications** - Transfer CPNP notifications to the new RP - Update CPNP with new RP information - Ensure all products are properly transferred #### 3. **Coordinate Transition** - Transfer Product Information Files (PIFs) to new RP (if applicable) - Transfer ongoing SUE cases - Update labeling and packaging with new RP information - Ensure continuity of regulatory obligations #### 4. **Terminate Previous RP** - Provide proper notice to previous RP (per contract terms) - Ensure all obligations are fulfilled - Complete any outstanding regulatory activities ### Key Considerations #### Market Continuity Products can typically remain on the market during transition, but you must: - Ensure regulatory obligations continue to be met - Have a valid RP at all times - Not have a gap in RP coverage #### PIF Transfer - Product Information Files must be accessible to new RP - Ongoing SUE cases must be transferred - Historical records may need to be retained #### Labeling Updates - All labeling must be updated with new RP information - This includes primary packaging, secondary packaging, and accompanying documents - Plan label print runs accordingly #### CPNP Updates - CPNP notifications must be updated with new RP information - All products must be properly transferred in CPNP - Ensure no gaps in CPNP coverage #### Timeline - Allow sufficient time for transition (typically 30-90 days) - Coordinate with both old and new RPs - Ensure no regulatory gaps ### Common Reasons for Changing RPs Manufacturers change RPs for various reasons: 1. **Service Issues** - Poor responsiveness, lack of support 2. **Cost** - Pricing changes, budget constraints 3. **Strategic Reasons** - Geographic preferences, additional services needed 4. **Compliance Concerns** - Regulatory issues, quality problems 5. **Business Changes** - Company restructuring, new requirements ### Best Practices 1. **Plan Ahead** - Don't wait until the last minute 2. **Coordinate Carefully** - Ensure smooth handover 3. **Document Everything** - Keep records of the transition 4. **Update All Materials** - Ensure labeling and CPNP are updated promptly 5. **Maintain Compliance** - Never have a gap in RP coverage ### Red Flags - ⚠️ New RP not ready to take over immediately - ⚠️ Gap in RP coverage - ⚠️ Incomplete PIF transfer - ⚠️ Delayed labeling updates - ⚠️ CPNP notifications not properly transferred - ⚠️ Unclear transition timeline ### Next Steps 1. Plan your RP transition carefully 2. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Find a new RP provider that meets 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](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)