Key terms

Our key terms, in plain English

Last updated 28 October 2026 (version 4).

This page is a plain-English summary of our Client Terms Pack (October 2026, version 4). It is not an offer and it does not form part of any agreement between us. The only binding terms are your Quote and the Client Terms Pack, including the signed Responsible Person Mandate and the documents it lists, which we send you in full before you pay or sign anything. Please read them, and do not rely on this page when deciding whether to work with us. If this page and the Client Terms Pack differ, the Client Terms Pack applies. We work only with businesses, not consumers.

The appointment

• You appoint us by signing a written mandate, and we accept it in writing, as Article 4 of the UK Cosmetics Regulation requires. We act as your Responsible Person from the start date in the mandate, which cannot be earlier than our acceptance.
• The appointment covers the products listed in the mandate, in Great Britain only. It does not cover Northern Ireland or any other market.
• We are not responsible for any unit placed on the market in Great Britain before the start date, or before we confirm in writing that a product has been notified and can go live.
• Products are added by a written change signed by both of us. They can be removed the same way, or by either of us giving notice.

Fees

• All fees are paid in full and in advance. We do not offer credit or payment plans.
• Prices are in pounds sterling. You pay any bank or currency charges so that we receive the full amount.
• We never charge, accept or pay interest of any kind, including late payment interest and interest on refunds or deposits, and we charge no late payment fees. If a payment is late we may suspend non-statutory services, take it from your deposit, end the appointment after 14 days, and recover our actual costs of collecting it, at cost.
• The order is: you sign the mandate and pay, we review your products, we confirm which products we accept, then we accept the mandate or decline. A binding agreement starts when you pay, but it does not make us your Responsible Person until we accept.
• If we decline all your products, we refund the annual fee in full within 14 days and keep the onboarding (setup) fee. If we decline some, we move you to the right pricing tier and refund the difference within 14 days. If you do not send what we ask for within 30 days, we may decline the products concerned. If we have not accepted within 60 days of receiving your payment, for a reason other than a delay on your side, you can cancel by email and we refund everything within 14 days. Safety report fees for work already instructed, and a priority review fee once our review has started, are not refundable.
• Once we have accepted the mandate, fees are not refundable, because our legal responsibility starts then. There are three exceptions. If we end the appointment on notice, or at once because continuing would expose us to a risk we cannot manage or because our insurers restrict cover, while you are not in breach, or you end it because we broke the terms, we refund the annual fee for each whole month left in the service year. The same applies if you leave because we transfer the agreement. If you paid two years upfront and the appointment ends before the second year starts (other than because we ended it for a reason in clause 14.3 of the Client Terms), we refund what you paid less one year at the standard annual fee. If we remove a single product on notice, or for one of those same reasons while you are not in breach, and your tier falls, we refund the difference between the two tier fees for each whole month left.
• A product added during the year costs a one-off £99, which covers its review and notification until your next renewal date. At renewal it counts towards your pricing tier. A change to a product's formula counts as a new product, because it needs a new review and notification. Changes to the label, artwork, claims, packaging, supplier or manufacturing site of an existing product are reviewed within your annual fee, with one re-check, unless the change needs a new safety report or a new notification, in which case it is charged as a new product (£99) and any safety report work is charged separately. Further review rounds on the same change are £99 per product each.
• Incident and recall work, and work during or after the run-off when you leave, is £95 an hour, paid in advance in 10-hour blocks. Any unused balance is refunded.
• The appointment rolls over each year until either of us ends it. We give at least 30 days' notice of your renewal price, and it never rises by more than 10% a year unless your number of products changes. If it goes up, you can leave on the renewal date instead of paying the new fee, by telling us within 14 days of receiving the new price.
• We may ask for a security deposit or a guarantee from your parent company or owner, depending on your products. We may also ask for a deposit, or a larger one, later, for example after an incident, enforcement action or a change in who owns you. We hold any deposit in a separate account in our name. It is security, not held on trust, and no interest is earned or paid on it. If we take an amount from it we tell you within 5 working days, and you top it up within 10 working days. We return it, less anything you owe, within 30 days after the later of 12 months after the appointment ends (36 months for products we treated as higher-risk) and the close of any open incident, claim or authority enquiry.

What we do

• Review your formulas, safety report, labels and claims so we can meet our duties as Responsible Person, and tell you in writing what must change.
• Notify each product on SCPN, keep the notification up to date, and confirm in writing when it can go live.
• Hold the product information file in English, at our address, for at least 10 years after the last batch is placed on the market in Great Britain, and produce it to the authorities when asked.
• Deal with the authorities, log reactions and report serious ones as the law requires.
• Take reasonable steps to follow changes to GB cosmetics law and tell you about changes we become aware of that affect your products.
• We aim to reply within 1 working day on safety matters sent to compliance@haldenrp.co.uk, and within 3 working days on anything else. These are targets, not guarantees. A working day is Monday to Friday, excluding bank holidays in England.
• Before we accept, and while we act for you, we will have in place professional indemnity and public and products liability insurance appropriate to our services, or a reserve of at least £5,000 kept for claims. On request we confirm which, and name the insurer.

We do our work with the reasonable care and skill of a competent UK Responsible Person. We do not promise that a product is safe or compliant, or that an authority or marketplace will accept a notification or listing. Our reviews do not replace your own responsibility for your products. We do not carry out safety assessments ourselves, act as importer or seller, handle goods or returns, or advise on other areas of law such as trade marks, customs or tax.

What you do

The main things you must do are below. The full list is in clauses 3 to 6 and 9 of the Client Terms.

• Give us complete and accurate information, including the full formula of every product, and keep it up to date.
• Tell us in writing at least 15 working days before any change to a formula, raw material supplier or grade, manufacturing site, packaging, pack size, label, product name or claims (including online and through influencers) reaches the GB market, and do not place the changed product on the market until we confirm in writing.
• Do not place a product on the market in Great Britain until we have confirmed it can go live.
• Send every complaint and reaction report to compliance@haldenrp.co.uk within 1 working day, however minor, including reports from other markets about the same formula. Tell us within 1 working day of any claim or legal letter about a product.
• Tell us within 1 working day of any recall, withdrawal, customs detention or enforcement action in any market, answer our safety questions within 24 hours, and keep batch and distribution records for 10 years.
• Before your products go live, hold product liability insurance of at least £1 million per occurrence and in the aggregate, covering injury or damage in Great Britain and claims in UK courts, extended to us as your Responsible Person, with your insurer waiving subrogation against us. Keep it for at least 24 months after our appointment ends (6 years of run-off cover if the policy is claims-made). You do not need it to sign or for us to start our review.
• Do not send us products containing PFAS. We do not accept them.
• Never send products, samples or customer returns to our address.

Safety comes first

While we are your Responsible Person, and afterwards for units placed on the market while we were, our legal duties come first. Without needing your consent, we can answer the authorities and report a serious reaction. If we reasonably believe a product is or may be unsafe or non-compliant, we can require it to be corrected, withdrawn or recalled. We decide whether a reaction is serious. If you do not act by our deadline, if we cannot reach you within 24 hours, or if an authority needs urgent action, we can take the action ourselves, in your name and at your cost.

Your label

Your pack carries our name and address as your UK Responsible Person, shown only as "Responsible Person (GB)", never as the maker, importer, distributor or seller, and alongside your own brand name. While the law allows it, which is currently until 31 December 2027, and only where we have agreed it in your product schedule, units whose labels already show an EU Responsible Person and meet EU rules can be placed on the GB market without our details. You must keep that EU Responsible Person (this route ends at once if you do not), and you must make sure it passes us any contact from a GB authority or consumer within 1 working day. We are still your Responsible Person and notified as such. Any new artwork or print run ordered after your start date must show our details.

Ending the appointment

• Either side can end it with 60 days' written notice. Our services continue as normal during the notice period.
• Either of us can end it at once in some cases, for example if you withhold information, refuse a recall we require, or leave fees unpaid 14 days after they are due, if continuing would expose us to a legal or regulatory risk we cannot properly manage, if our insurers restrict or exclude cover for you, or if we materially breach the terms and do not fix it within 14 days.
• A 30-day run-off follows, while you appoint a new Responsible Person or stop supplying Great Britain. From the date the appointment ends you must not place any unit on the market with us as Responsible Person, and by the end of the run-off you must relabel or withdraw stock you control that shows our details.
• If you appoint a new Responsible Person, we aim to give them a copy of your product information file within 10 working days of your written request, whether or not any fees are unpaid. We keep our own copy, for at least 10 years as the law requires and as long as we need it to meet our legal duties or deal with claims.

Confidentiality and data

Your formulas and documents stay confidential from the moment you first send them. We only share them where the law requires or where the Client Terms Pack allows, for example with the authorities, our insurers or a safety assessor bound by confidentiality. We may say publicly that we are your UK Responsible Person, for example by listing your brand name on our website, unless you tell us in writing that you object. We will not use your logo or publish a case study about you without your written consent. Personal data is handled under our Data Protection and Transfer Terms, which form part of the agreement, and our privacy notice.

Liability and law

• Our total liability for claims arising from events in any one service year is limited to the greater of five times the fees you paid for our own services (not deposits, assessor fees or third-party costs) in the 12 months before the first of those events, and £50,000. For a standalone service such as a paid label check, the limit is the greater of the fee you paid and £1,000. Nothing limits liability that the law does not allow to be limited.
• We are not liable for lost profit or sales, or for anything we do, or reasonably decide not to do, in good faith to meet our legal duties or answer an authority, even if it later turns out not to have been needed. This does not cover a negligent failure by us to provide our services. We are not liable for wasted stock or reprinting costs, except where they are caused by our negligence in a label or claims review for stock produced in line with our written confirmation, and then only up to the greater of the review fee and £1,000.
• You cover our losses arising from your products, the information you give us, a breach of the terms, third-party claims, authority action and any corrective action, including our legal costs as they arise, except to the extent a loss is caused by our own negligence, wilful default or material breach. This is not limited by our liability cap.
• Any claim against us must be started within 2 years of when you knew, or should reasonably have known, the facts behind it.
• We may transfer the agreement to a company that takes over our Responsible Person business, with at least 30 days' notice. If you do not want to continue, you can leave on the transfer date.
• The agreement is governed by the law of England and Wales. Before starting proceedings, senior people on each side try to resolve a dispute within 14 days. Disputes then go to the courts of England and Wales only, and you must not bring a claim against us anywhere else. We can serve court documents on you by email to your notices address and by courier to your registered address.

This is a summary for convenience of the October 2026 Client Terms Pack (version 4). It is not legal advice and is not part of our agreement. Ask us for the Client Terms Pack at hello@haldenrp.co.uk.