HCPC Brands EuropeResponsible Person (RP)
Every cosmetic product placed on the EU market must be assigned a Responsible Person — an EU-established party who takes on full legal accountability for that product's compliance. HCPC Brands Europe B.V. acts as your Responsible Person, so you can bring your products to the EU market without needing an entity of your own inside the Union.
What's Included
- Formal appointment — a written mandate accepted in accordance with Article 4 of the Cosmetics Regulation, naming HCPC Brands as your product's Responsible Person.
- Address on label — our EU address appears on your product labelling as required, alongside the mandatory notification details.
- PIF custody & access — we hold your Product Information File and make it available to competent authorities on request, in a language they can readily understand.
- Labelling compliance verification — we check that labelling meets the Cosmetics Regulation before market entry.
- Authority liaison — we act as the accountable contact point for competent authorities regarding your products.
- Cosmetovigilance — ongoing monitoring and mandatory reporting of serious undesirable effects.
Who Needs an EU Responsible Person
- Non-EU manufacturers exporting cosmetic products into the EU market for the first time.
- Importers bringing finished cosmetic products into the EU from outside the Union.
- Distributors who rebrand a product under their own name or trademark, or modify it in a way that could affect compliance.
- EU manufacturers who prefer to outsource the regulatory function rather than build in-house expertise.
What Stays With You
Acting as Responsible Person is strictly a regulatory role — HCPC Brands does not manufacture, formulate, package, or hold inventory of your products. Responsibility for the safety, quality, and formulation of the product itself remains with you and/or your manufacturer at all times, and all costs, fines, or claims connected to the product are passed through to the Client, as set out in our Responsible Person Agreement.
Regulatory Framework
Our Process
- 1. Intake — we review your product portfolio, current documentation status, and target EU markets.
- 2. Agreement — we formalise the Responsible Person mandate and confirm labelling requirements.
- 3. PIF & CPSR — we compile or review your Product Information File and Cosmetic Product Safety Report.
- 4. Notification — we submit your CPNP notification and confirm you're market-ready.
- 5. Ongoing mandate — cosmetovigilance monitoring and authority liaison continue for as long as we act as your RP.
Frequently Asked Questions
What is the Responsible Person under EU cosmetics law?
The Responsible Person (RP) is the natural or legal person accountable for a cosmetic product's compliance once it is placed on the EU market. By default this is the EU-based manufacturer, the importer of a non-EU product, or a distributor who rebrands or materially modifies a product — though the role can be formally mandated in writing to another EU-established party instead.
Does the Responsible Person need to be physically located in the EU?
Yes. The Responsible Person must be established within the EU, since EU authorities need an accountable, reachable party inside their jurisdiction. A company based outside the EU cannot act as its own Responsible Person and must appoint an EU-established party instead.
What happens if I already have a Responsible Person and want to switch providers?
A transition is possible at any time. It requires the outgoing and incoming Responsible Person to cooperate on transferring the Product Information File and updating the RP address on labelling and in the CPNP notification, so there is no gap in market compliance.
Who is legally liable if something goes wrong with my product once HCPC Brands is the RP?
HCPC Brands' role as Responsible Person is limited to the administrative and regulatory functions defined under the Cosmetics Regulation. All costs, fines, and claims connected to the product itself — its formulation, manufacturing, or safety — remain the Client's responsibility, as set out in the Responsible Person Agreement.
What does the Responsible Person actually do on an ongoing basis?
Beyond the initial appointment, the RP keeps the Product Information File up to date, monitors labelling compliance, liaises with competent authorities on request, and — through cosmetovigilance — monitors and reports serious undesirable effects for as long as the product remains on the market.
See also our Product Information File, CPSR, and Cosmetovigilance pages, or our full Cosmetics Glossary & FAQ.
Ready to appoint your EU Responsible Person?
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