How to switch your UK Responsible Person

Published 16 October 2026. Last checked 16 October 2026. 6 minute read. General information, not legal advice.

Brands change their UK Responsible Person for ordinary reasons: the price went up, replies got slow, the provider stopped covering a product type, or the brand outgrew a cheap starter service. Switching is not complicated, but the order matters. Done in the wrong order, you can end up unable to ship new stock, or with a label and a notification that no longer match.

This post covers what the law requires, where the official guidance is silent, and a sensible order to do things in.

What the law requires

The rules are in Regulation (EC) 1223/2009 as it applies in Great Britain, often called the UK Cosmetics Regulation.

A Responsible Person before sale. A cosmetic product may not be placed on the market unless there is a Responsible Person established in the UK (Article 4(1)).
A written mandate, accepted in writing. A third party becomes the Responsible Person by written mandate from the manufacturer or importer, and only once it accepts the designation in writing (Article 4(6) and (7)). Your new provider should give you a mandate to sign and should countersign it.
Notification before sale, and updates without delay. The Responsible Person notifies each product before it is placed on the market, including the address where the product information file is kept (Article 13(1)). If any of that information changes, it must be updated (Article 13(11)).
The label shows the Responsible Person. The container and outer packaging must show the name and address of the Responsible Person (Article 19(1)(a)). If more than one address is shown, the one where the product information file is kept must be highlighted.
The product information file stays available. It must be kept for ten years after the last batch was placed on the market, and be readily accessible to the authorities at the address given in the notification (Article 11).

Where the official guidance is silent

We could not find any GOV.UK or Office for Product Safety and Standards (OPSS) guidance that sets out, step by step, how a change of Responsible Person works inside SCPN, the UK's Submit Cosmetic Product Notifications service. In particular, the published guidance does not say whether a notification can be moved from one Responsible Person's account to another, or exactly what the outgoing Responsible Person should do with its notifications.

We also found no rule giving a grace period for stock already labelled with the old Responsible Person's details, and no legal provision on handing the product information file from one Responsible Person to another. That handover is a matter for your contracts. The SCPN service itself does say that your Responsible Person contact information must stay up to date both on SCPN and on your products placed on the market.

So agree in writing with both providers who does what in SCPN, and on what date. If anything is unclear, OPSS has a contact form on the SCPN support site with an option for "Updating Responsible Person details or team members".

A sensible order

Read your current contract. Check the notice period, any run-off or handover period, and what it says about handing over your product information file.
Get your documents together. Full formulas, safety reports, label artwork and anything else in the product information file. Ask your current provider for a copy of the file if they hold the only one.
Let the new provider review before you give notice. They need to check formulas, labels and safety reports against current UK rules. If they find gaps, you want to know before your old cover ends.
Sign the new mandate and get the new provider's written acceptance, with a clear start date.
Agree a switch date with both providers, so the SCPN changes happen on the same day and there is no gap.
Update SCPN as agreed with both providers, so the notification shows your new Responsible Person and the address where the file is now kept.
Update your labels. New print runs and new artwork should carry the new Responsible Person's name and address. Plan what happens to stock already printed with the old details, since we found no official grace period for it.
Update anywhere else the old details appear, such as your website and marketplace listings, and tell your importer or fulfilment provider.
Give notice to your old provider once the new arrangement is in place, and keep written confirmation of the end date.

Things that catch brands out

Ending the old contract first. If the old Responsible Person steps away before the new one is in place, the law makes your UK importer the Responsible Person by default, often without the importer realising it, and new products cannot be placed on the market until a Responsible Person has notified them on SCPN.
Not having your own copy of the file. If the only copy of your product information file sits with a provider you are leaving, the switch depends on them.
Northern Ireland. A Responsible Person based in Great Britain cannot act for Northern Ireland, which follows EU rules and needs a Responsible Person in Northern Ireland or the EU, with notification through the EU portal (CPNP). Switching your GB provider does not change that.
The 2027 EU label rule is a different thing. Until 31 December 2027, a product labelled with an EU Responsible Person can be sold in Great Britain without UK details on the pack. That rule is about EU labels. It does not help with stock labelled with a previous UK Responsible Person. More on it in our post on the 31 December 2027 label deadline.

How we handle a switch

If you move to us, we review your products before we accept the appointment, so you know about any gaps while your current cover is still running. If you ever leave us, either side can give 60 days' notice, a 30-day run-off follows, and we send your new Responsible Person a copy of your product information file within 10 working days of your written request. Our prices and key terms are published.

Thinking about switching? Tell us what you sell and we will quote.

Common questions

Can I switch my UK Responsible Person at any time?

Yes, subject to the notice period in your contract with your current provider. The law does not set a notice period. Check your contract before anything else.

Do I have to re-notify my products on SCPN?

Official guidance does not say. What the law does say is that the notification must show the current Responsible Person details and the address where the product information file is kept, and must be updated without delay when anything changes (Article 13). Agree with both providers who does what, and on which date.

Can I keep selling stock that shows my old Responsible Person?

We found no official grace period for stock labelled with a previous UK Responsible Person. Plan new print runs and what happens to existing stock before the switch date.

Does my 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.

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
OPSS guidance for Great Britain: gov.uk, Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (Great Britain)
OPSS guidance for Northern Ireland: gov.uk, Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013 (Northern Ireland)
SCPN service start page: submit.cosmetic-product-notifications.service.gov.uk
SCPN support contact form: support.cosmetic-product-notifications.service.gov.uk

This post is general information, not legal advice. It reflects the legislation and guidance as we found them on 16 October 2026.