Do I need an EU Cosmetics Responsible Person if I have an EU importer or distributor?

## Do I Need an EU Cosmetics Responsible Person If I Have an EU Importer or Distributor? **Yes, if you are a non-EU manufacturer placing cosmetic products on the EU market, you generally need an EU Cosmetics Responsible Person** regardless of whether you have an importer or distributor. The importer/distributor and the Responsible Person are different roles with different obligations. ### The Legal Framework Regulation (EC) No 1223/2009 states that **cosmetic products may only be placed on the market if a responsible person is designated within the Community**. This requirement is independent of whether you have an importer or distributor. ### Different Roles, Different Obligations The RP and importer/distributor have distinct responsibilities: #### EU Cosmetics Responsible Person - **Regulatory role** - Represents manufacturer for regulatory compliance - **Key responsibilities**: - Ensure product safety and compliance before placing on market - Maintain Product Information File (PIF) - Submit CPNP notifications - Ensure proper labeling compliance - Serve as contact point for authorities - Report serious undesirable effects #### EU Importer/Distributor - **Supply chain/commercial role** - Places products on the market or makes them available - **Key responsibilities**: - Verify products have appropriate markings and documentation - Verify RP is identified on labeling - Maintain complaint registers - Cooperate with authorities on market surveillance - Not place non-compliant products on the market ### Why Both Are Needed Even if you have an EU importer or distributor, you still need an RP because: 1. **Different Obligations** - The importer/distributor focuses on supply chain verification, while the RP focuses on regulatory compliance and documentation 2. **Regulatory Interface** - The RP serves as your regulatory interface with competent authorities 3. **PIF Management** - The RP must maintain Product Information Files 4. **CPNP Notification** - The RP is responsible for CPNP notifications 5. **Legal Responsibility** - The RP assumes legal responsibility for the products ### Can They Be the Same Company? **Typically no for the same products**—Regulation 1223/2009 requires separation of these roles to prevent conflicts of interest. However, a company can serve as RP for one manufacturer and importer/distributor for another. ### Practical Implications If you have an EU importer or distributor: 1. **You still need an RP** - The importer/distributor doesn't replace the RP requirement 2. **Coordinate between both** - Ensure both parties understand their roles 3. **Separate contracts** - You'll need separate agreements with each 4. **Different registrations** - Each may need separate registrations ### Best Practice Most manufacturers use: - **An independent RP** for regulatory compliance - **A separate importer/distributor** (or both) for supply chain activities This approach: - Eliminates conflict of interest concerns - Provides clearer regulatory oversight - Simplifies compliance documentation - Aligns with regulatory best practices ### Next Steps 1. Understand that RP and importer/distributor are separate requirements 2. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Find a qualified RP for your EU market access --- *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)