The Responsible Person for cosmetic products
The Responsible Person (RP) is the entity or person responsible for ensuring that the cosmetic product they place on the market is safe for use and complies with the Cosmetic Product Regulation. The RP can be an individual or a legally registered company and they must be located in the European Economic Area (EEA).
- There is no HPRA authorisation or certification to place a cosmetic product on the market.
- However, there must be an RP for every cosmetic product placed on the market in the EEA.
- The RP is obliged to ensure the product complies with the Cosmetics Regulation and must keep and maintain a product information file (PIF), demonstrating compliance with the regulation.
Who is the Responsible Person (RP)?
If you perform any of the following activities, you may be considered the RP for the product:
- Manufacture cosmetic products and place them on the EEA market under your own brand/trademark.
- Import cosmetic products from outside of the EEA.
- Alter pre-existing packaging and/or labelling of a product already on the market, such as rebrand it.
- Use a contact manufacturer to make cosmetic products and sell them under your own brand/trademark.
Our Guide to Cosmetic Products for Responsible Persons details some of the key obligations of the RP, many of which are listed above.
Certain RP obligations, in particular the generation of a product information file (PIF), containing a cosmetic product safety report (CPSR), and notification of a cosmetic product to Cosmetic Product Notification Portal (CPNP) must be met prior to placing the products on the market.
RPs are required to have all documentation in place prior to placing the product on the market.
Our information pack summarises the legal requirements to place cosmetic products on the European Economic Area market.
What if I import a cosmetic from outside the EEA but do not want to be the Responsible Person?
It is also possible to mandate another EU entity to act as RP for the products, which must be accepted in writing between both parties. The responsible person shall be based within the EU and their address should appear on the cosmetic product packaging.
If a company intends to sell cosmetic products solely as a distributor or retailer, and they are taking on the role of RP, please refer to Distribution or Retail of Cosmetic Products in Ireland.
Any specific queries may be sent to the Cosmetics section of the HPRA. Please see the Contact Us page.