EU responsible person: meaning under GPSR and EU cosmetics rules
Most products sold in the EU need someone established in the EU who answers for them.
Definition
EU responsible personAn EU responsible person is an economic operator established in the European Union who is answerable to market surveillance authorities for a product’s compliance. Under the General Product Safety Regulation this can be the EU manufacturer, an importer, an authorised representative with a written mandate, or a fulfilment service provider; under the Cosmetics Regulation 1223/2009, a responsible person in the EU must be designated for each cosmetic product.
Who can be the responsible person and what they do
Under GPSR Article 16, read with Article 4 of Regulation (EU) 2019/1020, a product cannot be placed on the market unless an economic operator established in the EU is responsible for it. That operator can be a manufacturer established in the EU, an importer, an authorised representative appointed by written mandate, or a fulfilment service provider where none of the others is established in the EU. Its tasks include keeping documentation available to authorities, cooperating with them and, under GPSR, regularly checking that products match their technical documentation.
Cosmetics have their own regime. Regulation (EC) No 1223/2009 requires a responsible person established in the EU for each product. A manufacturer outside the EU can designate one by written mandate; otherwise the importer is the responsible person. The responsible person holds the product information file, ensures the safety report exists and submits the CPNP notification.
Other markets use similar ideas with different rules. Great Britain requires a cosmetics Responsible Person with a UK address. Under MoCRA in the US, the responsible person is the manufacturer, packer or distributor whose name appears on the label. A non-EU brand should decide early who will act in each market, because the name and address go on the label and in online listings.
Treat this as general information; who should act for your product is confirmed with a licensed specialist during a project. See private label cosmetics in the EU and our compliance stage.
Responsible person in three regimes
| EU general products (GPSR) | EU cosmetics (1223/2009) | US cosmetics (MoCRA) | |
|---|---|---|---|
| Who it is | EU manufacturer, importer, authorised representative or fulfilment service provider | Person in the EU designated by mandate, or the importer | Manufacturer, packer or distributor named on the label |
| Must be based in | The EU | The EU | Not set by the definition; the name and address appear on the label |
| Key documents | Technical documentation available to authorities | Product information file, safety report | Safety substantiation records |
| Notification | No central notification | CPNP before placing on the market | Product listing with FDA |
Summary of official texts. Check the full rules for your product and market.
Related terms
GPSR
EU Regulation 2023/988 setting safety duties for consumer products, applicable since 13 December 2024.
CPNP
The EU portal where a cosmetic product is notified by its responsible person before sale.
MoCRA
The US 2022 law that added registration, listing and safety duties for cosmetics.
CE marking
The manufacturer’s mark that a product meets the EU harmonised rules that require it.
Frequently asked questions
Does a non-EU brand need an EU responsible person?
For most consumer products sold in the EU, yes. GPSR requires an economic operator established in the EU for each product, and cosmetics require a designated responsible person in the EU.
Can a marketplace or fulfilment provider be my responsible person?
A marketplace is not among the operators listed. A fulfilment service provider can be the responsible economic operator under GPSR only where no EU manufacturer, importer or authorised representative exists. For cosmetics, a responsible person must be designated under the Cosmetics Regulation.
Have a product idea? Check it before you buy stock.
Send a short brief. We tell you what we think, including when we think you should not do it.