Who can be the Responsible Person for a UK cosmetic product?

The UK Cosmetics Regulation sets out clearly who can serve as Responsible Person depending on how the product is made and sold:

You're a UK-based manufacturer

If you make the cosmetic product in the UK, you are automatically the Responsible Person unless you formally nominate someone else in writing. Your company name and UK address go on the label.

You're importing from outside the UK

If you import a product into the UK from another country, you automatically become the Responsible Person by default even if you are selling it under the original manufacturer’s brand name unless the overseas manufacturer has already formally appointed a different UK-based entity to act as their RP.

You're based outside the UK

If your business is outside the UK and you want to sell cosmetics in Great Britain, you must appoint a UK-based Responsible Person. This cannot be a PO box or a mail-forwarding address, it must be a real, reachable UK address.

This is the requirement that most catches out overseas brands entering the UK market. A EU Responsible Person or a US company address is not acceptable for UK sales. You need a UK entity.

You can appoint a third-party RP service

If you don't have a UK presence, you can engage a cosmetic compliance services company to act as your UK Responsible Person. Several such services exist. They will hold your Product Information File, handle OPSS notifications, and be the legal contact point for UK authorities.

This is particularly relevant for brands based in the EU, USA, or elsewhere who want UK market access post-Brexit without establishing a UK entity.

What must appear on the label?

The Responsible Person's full name and UK postal address must appear on both the immediate container (the tube, bottle, or jar) and the outer packaging (the box or carton), where the product has both.

If space is limited on a small product, the address can appear on an accompanying leaflet with a reference on the label pointing to it but this option should only be used where the product genuinely can't accommodate the information on-label.

What counts as acceptable: – Company name and full UK postal address – Individual's full name and UK postal address if a sole trader – Name of a compliance services company acting as third-party RP, with their UK address

What doesn't count:

• A website address alone
• An email address alone
• A PO box
• A virtual office address that cannot receive official correspondence
• An EU address even during the transitional period for existing products, new products require a UK RP from now

What happens if you don't have a Responsible Person? Selling a cosmetic product without a compliant Responsible Person on the label is a breach of the UK Cosmetics Regulation. The OPSS can:

1. Issue a compliance notice requiring the product to be withdrawn from sale until corrected
2. Impose financial penalties, fines have ranged from thousands to tens of thousands of pounds
3. Require a product recall if the non-compliance creates a safety risk
4. Pursue criminal prosecution in serious cases
5. Beyond the regulatory consequences, platforms like Amazon and Etsy are now checking for Responsible Person details in product listings.

Missing or incorrect RP information is one of the most common reasons UK cosmetics listings are suspended on marketplace platforms.