Do I need an EU RP if I sell cosmetics online to EU customers?

## Do I Need an EU RP If I Sell Cosmetics Online to EU Customers? **Yes, you need an EU Cosmetics Responsible Person if you sell cosmetics online to EU customers**, regardless of whether you use physical retail, e-commerce, or direct-to-consumer channels. ### The Key Principle According to Article 4 of Regulation (EC) No 1223/2009, **cosmetic products may only be placed on the market if a responsible person is designated within the Community**^{<a href="#cite-3">[1]</a>}. "Placed on the market" includes making products available to EU consumers through any channel, including online sales. ### Online Sales Are Still "Placed on the Market" The EU Cosmetics Regulation applies to products made available to EU consumers through: - ✅ E-commerce websites and online marketplaces - ✅ Direct-to-consumer (D2C) sales - ✅ Social media sales - ✅ Subscription box services - ✅ Online B2B sales - ✅ Physical retail stores - ✅ Any other distribution channel ### Why Online Sales Still Require an RP 1. **Regulatory Contact Point** - Authorities need an EU-established entity to contact for inspections, complaints, or recalls 2. **Product Safety** - The RP ensures products meet safety requirements before reaching consumers 3. **Documentation Access** - PIFs must be accessible to authorities within the EU 4. **Market Surveillance** - Online sales are subject to the same market surveillance as physical retail ### What This Means for Online Sellers If you're a non-EU brand selling cosmetics online to EU customers, you must: - [ ] Appoint an EU-established Responsible Person - [ ] Ensure products are properly notified in CPNP before sales begin - [ ] Maintain compliant Product Information Files (PIFs) - [ ] Ensure proper labeling (including RP information) - [ ] Have processes for reporting serious undesirable effects (SUEs) - [ ] Be prepared for authority inspections and requests ### Common Misconceptions **❌ "I only sell online, so I don't need an RP"** - **Reality:** Online sales are still "placed on the market" and require an RP **❌ "I ship from outside the EU, so I'm not subject to EU rules"** - **Reality:** If products are made available to EU consumers, EU regulations apply **❌ "I'm just a small online seller, so the rules don't apply"** - **Reality:** The RP requirement applies regardless of business size or sales volume **❌ "My marketplace handles compliance"** - **Reality:** Marketplaces may have their own requirements, but you still need an RP ### Online Sales Compliance Checklist Before selling cosmetics online to EU customers: - [ ] Appoint an EU-established Responsible Person - [ ] Complete CPNP notification for all products - [ ] Ensure PIFs are complete and accessible - [ ] Verify labeling includes RP information - [ ] Establish SUE reporting processes - [ ] Understand your obligations as a seller - [ ] Prepare for potential authority requests ### Practical Considerations for Online Sellers 1. **Cross-Border Complexity** - Different EU countries may have additional requirements 2. **Language Requirements** - Labels and product information may need to be in local languages 3. **Shipping and Import** - Consider who handles import compliance if shipping from outside EU 4. **Marketplace Requirements** - Some platforms (Amazon, eBay, etc.) may require additional documentation ### Next Steps 1. Verify your sales model and target markets 2. Appoint an EU Cosmetics Responsible Person before beginning sales 3. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Find providers experienced with online sellers --- *Written by **Lo H. Khamis**, Regulatory Experts. [Connect on LinkedIn](https://www.linkedin.com/in/lo-h-khamis) for regulatory guidance.* ### Official Sources: <a id="cite-3"></a>[1] [Regulation (EC) No 1223/2009 - Article 4](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)