Responsible Person Option Strategies

Establishing the Right Responsible Person Option Strategy for the UK and EU Markets

Navigating the regulatory requirements of the UK and EU can be challenging when bringing cosmetic products to the UK or EU market. One major decision is determining the entity that will act as the Responsible Person (RP).

Under the Cosmetics Regulation in both the UK (Schedule 34 of the Product Safety & Metrology etc (Amendment etc) (EU Exit) Regulations 2019) and the EU (Regulation EC No 1223/2009), each cosmetic product placed on the market must be associated to a RP within the UK/EU respectively. An RP is defined as a ‘legal or natural person’ (usually a business) and it is their responsibility to ensure product compliance with Cosmetics Regulations. 

A brand can act as their own RP or you have the option to use a third party RP to provide the service for you. However, since Brexit, the EU and the UK are separate, and therefore, a Responsible Person is required in both markets. This means that you are required to have separate addresses, one in the UK and one in the EU.

In this blog, we’ll explore the different RP options available — setting up as your own RP or partnering with a third-party RP — and break down the pros and cons of each.

1. Becoming Your Own Responsible Person (RP)

2. Partnering with a Third-Party Responsible Person (RP)

Overall choosing your RP will depend on the overall business needs. Bloom can offer advice and discuss in more detail what would be the best option for you. We can also provide assistance in case you want to set up your brand as your own RP in the UK or in the EU. If you feel a third-party RP is a more suitable option, we also have a number of trusted contacts we are happy to recommend.

Olivia Santoni