Can I use one EU RP for multiple products and product variants?

## Can I Use One EU RP for Multiple Products and Product Variants? **Yes—one RP can manage multiple SKUs/variants**, but each cosmetic product still needs its own compliant documentation and notification. Understanding how this works helps you scale efficiently. ### The General Rule According to Regulation (EC) No 1223/2009, **one Responsible Person can manage multiple cosmetic products**^{<a href="#cite-18">[1]</a>}. However, each cosmetic product requires: - ✅ Its own Product Information File (PIF) - ✅ Its own CPNP notification - ✅ Its own safety assessment and CPSR - ✅ Its own compliance documentation ### Product vs. Variant **Product:** A distinct cosmetic product with its own formulation - Example: "Moisturizing Cream" and "Anti-Aging Serum" are different products **Variant:** Different versions of the same product (shades, fragrances, etc.) - Example: "Lipstick - Red" and "Lipstick - Pink" may be variants of the same product ### One RP, Multiple Products **You can use one RP for:** - ✅ Multiple distinct products - ✅ Product variants (shades, fragrances, etc.) - ✅ Entire product catalog - ✅ Multiple brands - ✅ Different product categories **Each product still needs:** - [ ] Its own PIF - [ ] Its own CPNP notification - [ ] Its own safety assessment - [ ] Its own compliance documentation ### Practical Considerations **For Product Portfolios:** - One RP can handle your entire catalog - Each product needs individual documentation - RP should have systems to manage multiple products - Consider RP's capacity for your product volume **For Product Variants:** - Variants may share some documentation - Each variant may need separate CPNP notification - Safety assessment may cover variants together - Verify with RP how variants are handled ### Multi-Product RP Checklist When using one RP for multiple products: - [ ] Verify RP can handle your product volume - [ ] Understand how variants are managed - [ ] Confirm each product gets its own PIF - [ ] Verify each product gets CPNP notification - [ ] Understand pricing structure (per product vs. portfolio) - [ ] Ensure RP has systems for multi-product management - [ ] Verify turnaround times for multiple products ### Benefits of One RP for Multiple Products **Advantages:** - ✅ Single point of contact - ✅ Consistent processes - ✅ Potentially better pricing for volume - ✅ Easier coordination - ✅ Unified compliance approach **Considerations:** - RP capacity for your volume - Pricing structure - Turnaround times - Systems for managing multiple products ### RP Provider Selection When selecting an RP for multiple products, ask: 1. **"Can you handle our product portfolio size?"** - Verify capacity and systems 2. **"How do you manage product variants?"** - Understand variant handling 3. **"What's your pricing structure for multiple products?"** - Per product, per brand, or portfolio pricing 4. **"What are turnaround times for multiple products?"** - Understand timelines for portfolio 5. **"Do you have systems for managing multiple SKUs?"** - Verify they can scale ### Scaling Considerations **For Large Portfolios:** - Ensure RP has capacity - Verify systems can handle volume - Understand pricing for scale - Confirm turnaround times remain reasonable **For Growing Portfolios:** - Choose RP that can scale with you - Understand how new products are added - Verify processes for adding products - Confirm pricing doesn't become prohibitive ### Common Mistakes - ❌ Assuming one PIF covers all products - ❌ Not notifying each product in CPNP - ❌ Not understanding variant requirements - ❌ Not verifying RP capacity - ❌ Not clarifying pricing structure ### Best Practices 1. **Verify Capacity** - Ensure RP can handle your product volume 2. **Understand Variants** - Clarify how variants are managed 3. **Confirm Documentation** - Verify each product gets proper documentation 4. **Clarify Pricing** - Understand pricing structure for multiple products 5. **Plan for Growth** - Choose RP that can scale with you ### Next Steps 1. Understand your product portfolio and variants 2. Verify RP can handle your volume 3. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Find providers experienced with multi-product portfolios --- *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-18"></a>[1] [Regulation (EC) No 1223/2009 - Article 4, Article 11, Article 13](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)