Halden Do overseas cosmetics brands need a UK Responsible Person?
If you make cosmetics outside the UK and sell them to customers in England, Scotland or Wales, someone in the UK has to be legally responsible for them. That someone is the Responsible Person. This post explains who that is by default, when a brand should appoint one, and what the role involves.
What the law says
The rules are in Regulation (EC) 1223/2009 as it applies in Great Britain, often called the UK Cosmetics Regulation. Article 4(1) is short:
A cosmetic product may not be placed on the market unless there is a responsible person established in the United Kingdom.
GOV.UK lists who that can be: the manufacturer, the importer, a distributor that labels the product as its own, or a company or person appointed and authorised by the manufacturer or importer. Whoever it is, they must be established in the UK.
Who the Responsible Person is
- Made in the UK by a UK company: the manufacturer.
- Imported: the importer, meaning the business established in the UK that places the product from outside the UK on the market. The Office for Product Safety and Standards (OPSS) describes the importer as the Responsible Person by default.
- Appointed: a UK importer or manufacturer can appoint another UK-established person by written mandate. That person becomes the Responsible Person once they accept in writing (Article 4).
- A distributor that changes things: a distributor becomes the Responsible Person if it sells the product under its own name or trademark, or alters a product already on the market in a way that could affect compliance (Article 4).
For most overseas brands, the practical question is whether your UK importer or distributor is willing and equipped to carry these duties for your products. If they are not, you can appoint a specialist Responsible Person instead.
Selling online from outside the UK
The OPSS guidance for Great Britain and the Trading Standards guidance on Business Companion both explain the importer rule, but we found no official guidance that deals specifically with a brand outside the UK posting orders directly to UK customers. Both define an importer as a business established in the UK.
Our view, which is an interpretation rather than official guidance: if you sell into Great Britain, do not rely on there being an importer who has taken on the role. Appoint a UK Responsible Person so that someone established in the UK holds your file, notifies your products and can answer the authorities.
What a Responsible Person does
- Notifies each product before sale. Notification is made electronically to the Secretary of State on the Submit Cosmetic Product Notifications service (SCPN), and updated without delay when anything changes (Article 13). An EU CPNP notification does not count. Our SCPN guide lists what is needed.
- Holds the product information file. OPSS says the file must be kept up to date, in English, and available to the authorities at the UK address given in the notification, for ten years after the last batch was placed on the market (Article 11).
- Appears on the label. The pack shows the name and address of the Responsible Person, and imported products must show their country of origin (Article 19(1)(a)).
- Reports serious undesirable effects. The Responsible Person and distributors must notify the Secretary of State without delay of serious undesirable effects they know about, or could reasonably be expected to know about (Article 23).
- Makes sure the product is compliant. That includes a safety assessment (the cosmetic product safety report) and checking formulas and labels against the current GB rules, which have started to differ from the EU's.
EU brands and the 2027 label rule
Until 31 December 2027, a product whose label meets the EU rules and shows an EU Responsible Person is treated as meeting the GB label requirement for the Responsible Person's name and address (Article 19(1)(ab)). That is a label rule only. You still need a UK Responsible Person and an SCPN notification now. We explain the deadline in our post on the 31 December 2027 label deadline.
Northern Ireland
Northern Ireland follows EU cosmetics rules. It needs a Responsible Person in Northern Ireland or the EU, with notification through the EU portal (CPNP). A Responsible Person based in Great Britain, including us, cannot cover Northern Ireland.
What happens if nobody takes it on
The SCPN service says that not notifying can lead to a fine and a prison term of up to 3 months, with an unlimited fine in England and Wales. OPSS also says the authorities have the powers they need to stop further distribution or sale of a product if the Responsible Person is not taking the necessary action.
How we help
We are a UK Responsible Person desk in Bristol for brands based outside the UK, covering Great Britain only. We review your formulas and labels before we accept, notify each product on SCPN, hold your product information file and deal with the authorities. Our prices are published, and our free label check gives you a quick first look at what on your pack may need changing for Great Britain.
Common questions
Do I need a UK Responsible Person if I am based outside the UK?
If your products are sold in Great Britain, yes. A cosmetic product may not be placed on the GB market unless there is a Responsible Person established in the UK (Article 4(1)). Where a product is imported, the UK importer is the Responsible Person by default, unless a UK-established person is appointed by written mandate and accepts in writing.
Does my EU Responsible Person cover Great Britain?
No. An EU Responsible Person is not established in the UK, and an EU CPNP notification does not count in Great Britain. Until 31 December 2027 a label showing an EU Responsible Person is accepted in GB, but you still need a UK Responsible Person and an SCPN notification now.
Can my UK distributor or importer be the Responsible Person?
Yes. A UK importer is the Responsible Person for the products it places on the market, and a distributor becomes one if it sells under its own name or trademark, or alters a product in a way that could affect compliance. Whoever it is, agree it in writing so everyone knows who holds the duties.
Does a UK Responsible Person cover Northern Ireland?
Not if they are based in Great Britain. Northern Ireland follows EU rules and needs a Responsible Person in Northern Ireland or the EU, with notification through the EU portal (CPNP).
Sources
- Regulation (EC) 1223/2009 as it applies in GB, Article 4: legislation.gov.uk/eur/2009/1223/article/4
- Article 11 (product information file): legislation.gov.uk/eur/2009/1223/article/11
- Article 13 (notification): legislation.gov.uk/eur/2009/1223/article/13
- Article 19 (labelling): legislation.gov.uk/eur/2009/1223/article/19
- Article 23 (serious undesirable effects): legislation.gov.uk/eur/2009/1223/article/23
- OPSS guidance for Great Britain: gov.uk, Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (Great Britain)
- GOV.UK, Submit a cosmetic product notification: gov.uk/guidance/submit-a-cosmetic-product-notification
- SCPN service start page: submit.cosmetic-product-notifications.service.gov.uk
- Business Companion, cosmetic products: businesscompanion.info
This post is general information, not legal advice. It reflects the legislation and guidance as we found them on 27 October 2026.