Responsible Person (RP): UK & EU Compliance for Cosmetics & General Products (Including GPSR)
Placing cosmetic or general consumer products on the UK or EU market brings strict legal responsibilities. For cosmetics, businesses must appoint a Responsible Person (RP). For general products, the General Product Safety Regulation (GPSR) requires that an EU-based economic operator takes on defined compliance duties before goods are sold to consumers.
At Conformity Services Ltd, we provide both Responsible Person services for cosmetics and can act as your EU economic operator for GPSR compliance — thanks to our established European presence.
Responsible Person Duties (Cosmetics)
For cosmetics, the Responsible Person (RP) is legally required under:
UK: The UK Cosmetics Regulation (Product Safety & Metrology Regulations 2019).
EU: Cosmetics Regulation (EC) No 1223/2009.
The RP ensures:
Product Safety & Compliance – Verifies formulations meet safety and ingredient restrictions.
Labelling & Packaging – Confirms ingredient lists, warnings, durability dates, and batch codes are correct.
Product Information File (PIF) – Maintains full documentation for inspection.
Market Notifications – Submits cosmetic products to the UK SCPN or EU CPNP portals.
Adverse Event Monitoring – Reports serious undesirable effects to authorities.
Regulatory Contact Point – Acts as the official contact during audits and enforcement actions.
Without an RP, cosmetics cannot legally be sold in the UK or EU.
General Products & GPSR Obligations
The new EU GPSR (Regulation (EU) 2023/988), applying from December 2024, strengthens consumer product safety rules. Unlike cosmetics, general consumer products do not have an “RP.” Instead, they must have a designated economic operator in the EU responsible for compliance.
Who can act as an economic operator?
The manufacturer (if based in the EU).
The importer (for non-EU products).
An authorised representative or a fulfilment service provider established in the EU such as Conformity Services.
Key obligations under GPSR:
Product Safety – Products must be safe under intended and foreseeable use.
Traceability – The EU operator’s contact details must be on the product, packaging, or accompanying documentation.
Documentation – Maintain technical files, risk assessments, and conformity records.
Safety Information – Provide instructions and warnings in clear, accessible language.
Incident Reporting – Notify authorities of any product-related safety issues.
UK vs EU Compliance
UK Market
Cosmetics: Require a UK-based Responsible Person.
General products: Governed by the UK GPSR (aligned with EU rules but managed separately).
EU Market
Cosmetics: Require an EU-based Responsible Person.
General products: Must have an EU economic operator in place under the GPSR.
For businesses selling in both regions, this often means appointing separate entities to cover UK and EU obligations.
Why Partner with Conformity Services Ltd?
At Conformity Services Ltd, we make compliance straightforward by providing:
UK & EU Responsible Person services for cosmetics.
EU Economic Operator services for general products under GPSR, thanks to our European presence.
Ongoing monitoring, documentation management, and regulatory updates to keep your business market-ready.
This allows you to focus on growth while we ensure your products stay compliant, safe, and legally placed on the market.
Conclusion
The Responsible Person role applies to cosmetics, while the EU GPSR requires an economic operator for general consumer products. Both functions ensure safety, traceability, and accountability in the marketplace.
With our UK base and EU entity, Conformity Services Ltd can act as your Responsible Person and EU economic operator, giving SMEs one trusted partner for compliance across both jurisdictions.