Distribution or retail sale of cosmetic products in Ireland
A 'distributor' is any person within the supply chain, other than the manufacturer or the importer, who makes a cosmetic product available on the Irish market. This includes commercial activity, whether in return for payment or free of charge.
This definition also includes the retailer.
Accordingly, this guidance is relevant to distributors of cosmetic products who are:
- persons placing cosmetic products on the market in Ireland for which an RP has already been designated.
- persons importing cosmetic products into the EEA for which an RP has already been designated within Europe.
- retailers of cosmetic products including professionals supplying cosmetic products as part of a service.
If a company intends to sell cosmetic products solely as a distributor or retailer, and they are not taking on the role of RP, please refer to our Guide to distribution of cosmetic products in Ireland.
What are the distributor/retailer requirements when selling cosmetic products?
All retailers who sell cosmetic products in physical stores and/or online must carry out the following:
- Confirm that certain important information has been included on the label of a cosmetic product.
- Take due care and avoid any unnecessary risks in the purchase of cosmetic products from suppliers.
- Take steps to make a product safe if there is a safety concern.
- Inform suppliers and/or the HPRA if a customer experiences an undesirable effect (adverse reaction) after using a cosmetic product.
- Ensure products are stored and transported properly to avoid any negative impact on the safety.
What do distributors/retailers need to check on the product label?
- That the text on the label is in English, in Irish, or both.
- That the best before date, where this is relevant to the product, has not passed.
- That an ingredient list, a batch number or reference ID, and a European address is present on the label.
In the case of soap, bath ball or any other small product where it is not possible to list the ingredients, this information should appear on a notice immediately beside the product.
What checks must distributors/retailers carry out if they purchase a cosmetic product over the internet to sell in their premises?
If you are selling a cosmetic product that you have purchased online you must carry out the same checks listed above.
What records do distributors/retailers need to keep?
Distributors and retailers should keep records of all their suppliers of cosmetic products. Invoices and/or delivery dockets should be kept for three years. These will be required in the event of a product recall.
Distributors should also keep records of who they have supplied to i.e. other distributors or retailers. These will be required in the event of a product recall.
Records of the labelling checks performed should also be kept.
What actions should a distributor/retailer take during a product recall?
In the event that an unsafe product is placed on the Irish market, a retailer is required to cooperate with their supplier and with the HPRA in recalling the product from the market.
What should distributors/retailers do if a customer experiences an undesirable effect?
Reporting of undesirable effects is important to ensure the ongoing safety of cosmetic products.
If a customer experiences an undesirable effect with a cosmetic product that you have sold to them, the customer should be asked to complete this report form and send it to us.
The distributor or retailer should also contact the company at the European address on the label.