UK Responsible Person for overseas sellers of cosmetics

To sell cosmetics to consumers in Great Britain, every product needs a Responsible Person established in the UK. An EU responsible person does not fill the role. The UK Responsible Person notifies each product to the Office for Product Safety and Standards (OPSS) in the UK’s SCPN service before it is placed on the market, and keeps the product information file in English. Great Britain is England, Scotland and Wales. This page is only what the UK adds to the EU cosmetics responsible person rule. The other UK rules are on the United Kingdom page.

The Responsible Person must be established in the UK

The UK text of the Cosmetics Regulation says it in Article 4(1): a cosmetic product may not be placed on the market unless there is a responsible person established in the United Kingdom (Article 4). The EU text asks for a person established within the EU. The two are separate roles, so a seller in both markets has two.

Article 4 names who the Responsible Person is:

OPSS puts it in plainer words. The Responsible Person can be a business or an individual, including a sole trader, and it must have a UK established address. That address does not include a mail-forwarding or PO box address (OPSS). The guidance lists the manufacturer, the importer, a distributor that labels the product as its own, and an appointed company or person named by the manufacturer or the importer.

A seller shipping from abroad to UK customers has no UK importer. That seller appoints a person established in the UK by written mandate, and the person accepts in writing. Article 4(6) names an importer or a UK-established manufacturer as the one who designates. OPSS reads it as open to any manufacturer: “It is possible for a Manufacturer or Importer to authorise a third party to act as the Responsible Person via a written mandate”, and the third party “must be located in the UK” and accept the mandate in writing (OPSS, Great Britain guidance, paragraph 26). An importer “must by definition be based in the UK” (paragraph 25), so an overseas seller is not its own importer.

What the Responsible Person does for Great Britain

The duties are those of the EU rule, listed in the EU guide. These are the ones the UK changes:

• Notify the product to OPSS, not the EU portal. See the next section (Article 13).
• Keep the product information file in English, readily accessible to the authorities at the address notified in SCPN (Article 11(3), (4)). The UK safety assessor and the UK Annex I are in the safety report guide.
• Give the authorities information and documents in English when they ask for them (Article 5(4)).
• Report serious undesirable effects to OPSS. The form goes to seriousundesirableeffects@businessandtrade.gov.uk (OPSS).

The notification goes to OPSS in SCPN, not the CPNP

Great Britain replaced the CPNP with its own service, Submit cosmetic product notifications (SCPN). The Responsible Person signs in with a GOV.UK One Login and notifies every cosmetic product available to consumers in Great Britain (SCPN). A CPNP notification does not cover Great Britain: Article 13 asks for the information to be submitted to the Secretary of State.

• Before the product goes on the market: category and name, the Responsible Person’s name, the address where the product information file is kept, a named contact for urgent enquiries, any nanomaterials and CMR substances, and the frame formulation (Article 13(1)). The EU text asks in addition for the country of origin of an imported product and the EU country of first sale (EU Article 13). The UK text does not.
• When it goes on the market: the original label and, where legible, a photograph of the packaging (Article 13(2)).
• After that: any change is updated without delay (Article 13(11)).
• Nanomaterials: a product with a nanomaterial other than a colourant, UV-filter or preservative listed in the Annexes (those regulated under Article 14) is notified at least six months before it is placed on the market (Article 16(1), (3)).

SCPN search access is restricted to competent authorities, mainly Trading Standards, and the National Poisons Information Service (OPSS). The SCPN service page and the OPSS guidance name no fee. How SCPN compares with the CPNP is in the CPNP guide.

The label may carry the EU responsible person’s details until 31 December 2027

The pack must show the name and address of the Responsible Person, and the country of origin for an imported product (Article 19(1)(a)). Article 19(1)(ab) treats that as met, for seven years from the end of the transition period, where the pack complies with the EU rule, that is, shows the EU responsible person (Article 19). SI 2022/1393 stretched the period from two years to seven (regulation 7). OPSS dates the end at 31 December 2027 (OPSS, paragraph 81).

From 1 January 2028 the pack for Great Britain shows the UK Responsible Person. EU law still asks for the EU responsible person’s name and address on a pack sold in the EU, so a pack sold in both markets carries both.

OPSS’s consumer guidance lists “the name and address of the Responsible Person” on the label without saying whose. The transition above answers that: until 31 December 2027 the details may be the UK or the EU responsible person’s. It does not widen who may be the Responsible Person.

The label information on the contents, the date of minimum durability, the precautions and the function must be in English, whether or not it is also in another language (regulation 5(3)).

Northern Ireland uses the EU test, not the Great Britain one

Northern Ireland applies the EU Cosmetics Regulation under the Windsor Framework. A seller who ships there meets different rules from a seller who ships to England, Scotland or Wales:

An EU responsible person that notifies in the CPNP therefore serves Northern Ireland. It does not serve Great Britain. For Great Britain you need a UK one, even when the EU one is the same company, because the role is held by a person established in the UK.

A Northern Ireland business that sells a qualifying Northern Ireland product in Great Britain follows Article 5A instead. If it is the Responsible Person under Northern Ireland law, it is treated as complying with most Great Britain obligations, including labelling and safety assessment, and it sends certain information to the Secretary of State (OPSS, Great Britain guidance, paragraph 29).

What it costs

The UK sets no fee for the notification: the SCPN service page and the OPSS guidance name none. The law sets no fee for a Responsible Person either. A service provider’s price for a UK Responsible Person is agreed between you and the provider. The EU guide compares what providers publish, EU and UK, in what a cosmetics responsible person costs.

What happens if you do nothing

Without a Responsible Person established in the UK the product may not be placed on the market in Great Britain (Article 4(1)). The offences attach to the duties in the listed Articles, including those the Responsible Person owes under Article 5, and to ignoring an enforcement notice. Article 4 itself is not among the provisions listed in Schedule 4 (Schedule 4). SCPN states the result for a product not notified: “You may face a fine and a prison term of up to 3 months”, unlimited in England and Wales and up to £5,000 in Scotland and Northern Ireland (SCPN). The statutes give more detail for a breach under regulation 13(1) or (4): the statutory maximum is unlimited in England and Wales (LASPO 2012, section 85(1)) and £10,000 in Scotland (Criminal Procedure (Scotland) Act 1995, section 225(8)), and level 5 is £5,000 in Scotland. Northern Ireland keeps a cap on the fine, and no figure is given here.

An enforcement authority that requires measures under Article 25 gives written notice with a time limit, and no proceedings for the offences in regulation 12(1) start before that time limit has run out (regulation 8, regulation 12(4)). The notice can be challenged in court within 21 days (regulation 14). The Secretary of State and local Trading Standards enforce in England, Wales and Scotland. District councils enforce in Northern Ireland (regulation 2).

What does not apply here

• An EU responsible person for Great Britain. It does not satisfy Article 4. It appears on the pack only under the label transition above.
• The general product-safety responsible person. Under the General Product Safety Regulations 2005 the duties sit with the producer as that law defines it. The United Kingdom page sets out what does not apply and the EU responsible person guide covers the EU role. Cosmetics have their own Responsible Person under the Cosmetics Regulation.
• The medical-device UK Responsible Person. The MHRA requires a manufacturer abroad to appoint a UK responsible person for medical devices (MHRA). That is a separate role under separate law and does not cover cosmetics.

The 2025 Act has not changed this rule

The Product Regulation and Metrology Act 2025 received Royal Assent on 21 July 2025. It lets the Secretary of State make product regulations, including requirements to appoint authorised representatives, and it reaches people who control an online marketplace (section 2). Its list of excluded products names food, medicines and medical devices and a few other categories, not cosmetics (Schedule). The Cosmetics Regulation’s Article 4 shows no amendment since it was substituted on 31 December 2020, and the four cosmetics instruments of 2025 and 2026 on legislation.gov.uk, SI 2025/413, 2025/901, 2026/23 and 2026/109, change ingredient restrictions only.