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Importing cosmetics into Great Britain? You may already be the Responsible Person

Published 5 November 2026. Last checked 5 November 2026. 5 minute read. General information, not legal advice.

Importing cosmetics into Great Britain? You may already be the Responsible Person. Article 4(5), UK Cosmetics Regulation.

If you bring cosmetics into Great Britain from abroad and sell them, UK law treats you as the Responsible Person for those products unless you have formally handed the role to someone else. That applies whether the stock comes from South Korea, China, the US or the EU, and whether you sell on your own website, Amazon or to shops.

Many importers only find this out when a marketplace asks for SCPN details or a Trading Standards officer asks for the product file. This guide explains where the rule comes from, what it puts on you, and the two ways to deal with it.

Where the rule comes from

The UK Cosmetics Regulation (Regulation 1223/2009 as it applies in Great Britain) says a cosmetic product may not be placed on the market unless there is a Responsible Person established in the United Kingdom for it (Article 4(1)).

It then says who that person is. For imported products, Article 4(5) is short: any importer placing a cosmetic product on the market is the Responsible Person for that product, subject to the option to designate someone else.

An importer, under Article 2, is a person established in the UK who places a cosmetic product from a country outside the UK on the market. So if your UK business buys finished cosmetics from an overseas brand or supplier and puts them on sale in GB, you are the importer.

The importer of a cosmetic product, whether from the EU or another country, becomes a Responsible Person by default.

That is how the government's GB guidance puts it, adding that the importer may appoint an agent to act as the Responsible Person for them.

What being the Responsible Person means

The Responsible Person is the one the authorities hold accountable for the product being safe and legal in GB. In practice that includes:

  1. Notification. Each product must be notified on the UK's Submit Cosmetic Product Notifications service (SCPN) before it goes on sale. An EU CPNP notification does not cover Great Britain. See our SCPN guide.
  2. The product file. The Responsible Person must keep a product information file, including the cosmetic product safety report, and keep it readily available to the authorities at the address given in the SCPN notification. If the label shows more than one address, that address must be the one highlighted.
  3. The label. The Responsible Person's name and address go on the pack, and for imported products so does the country of origin. GOV.UK says a UK established address does not include mail forwarding or PO box addresses.
  4. Safety and problems. Checking the product meets the rules, reporting serious undesirable effects, and taking action if something goes wrong.

None of this is a formality. If a product is notified by nobody, or the file cannot be produced, the importer is the person the authorities come to.

The EU label concession, and what it doesn't cover

There is one easement that often gets misread. For a transition period of seven years from 1 January 2021, products can carry an EU or EEA Responsible Person's name and address on the label instead of the UK Responsible Person's, provided the label otherwise meets the EU labelling rule. That runs to the end of 2027. More on this in our post on the 2027 deadline.

That concession is about the label only. It does not remove the need for a UK Responsible Person, an SCPN notification, or a product file available at the UK Responsible Person's notified address. And it only helps products whose labels carry an EU or EEA Responsible Person's name and address. Stock from Korea, China or the US without one needs the UK Responsible Person's details on the label now.

Your two options

Option 1: take on the role yourself. Some importers do. It means getting the safety reports, building and holding the product files, notifying every product on SCPN, putting your business name and UK address on the labels, and handling any complaints or authority contact. It suits importers with regulatory knowledge in house and a small, stable range.

Option 2: designate someone else in writing. Article 4(6) lets an importer designate a person established in the UK as the Responsible Person by written mandate. Under Article 4(7), once that person accepts the designation in writing, they are the Responsible Person. Their name and address then go on the label.

Either way, the mandate and the acceptance need to be in writing. A verbal agreement, or a supplier saying "it's covered", is not enough.

Questions to ask your supplier before you buy stock

If the answers are vague, assume the role falls to you.

What this means for your brand

If you are a UK business importing someone else's cosmetics, check today whether a Responsible Person is already in place for each product you sell. If not, the law already treats you as that person. Decide whether you will run the role yourself or designate a UK Responsible Person in writing, and do it before the next shipment goes on sale.

If you would like us to take on the role, ask for a quote, or check a label for free first.

Common questions

Is the importer the Responsible Person for cosmetics in the UK?

Yes, by default. Under Article 4(5) of the UK Cosmetics Regulation, an importer placing a cosmetic product on the market in Great Britain is the Responsible Person for it, unless they designate someone else in writing and that person accepts in writing.

Can an importer hand the Responsible Person role to someone else?

Yes. Article 4(6) lets an importer designate a person established in the UK as the Responsible Person by written mandate. Under Article 4(7), that person becomes the Responsible Person once they accept the designation in writing.

Does an EU Responsible Person on the label cover Great Britain?

Only for the label, and only until the end of 2027. Products can carry an EU or EEA Responsible Person's name and address instead of the UK one during the transition, but a UK Responsible Person, an SCPN notification and an accessible product file are still needed now.

Sources

This post is general information, not legal advice. Last checked 5 November 2026.