Recurring mandate
EU Responsible Person services.
The legally required Responsible Person for your cosmetics in the European Union, with your full dossier handled in one place.
What the law requires
An EU-established Responsible Person for every product.
Under EU Cosmetics Regulation 1223/2009, no cosmetic product may be placed on the EU market without a Responsible Person established in the EU. That Responsible Person must hold a Product Information File, keep a signed Cosmetic Product Safety Report on file, and notify the product through the CPNP portal before it goes on sale. The Responsible Person is the legal point of contact for authorities and carries responsibility for the product's compliance.
The role can be filled by the manufacturer, the importer, a distributor, or a third-party service provider. A brand that is not established in the EU cannot act as its own Responsible Person and cannot access CPNP directly. That leaves two options: set up an EU entity, or appoint a Responsible Person already established in the Union. For most indie and growing brands, appointing a third-party Responsible Person is the practical route.
The requirement is size-blind. A one-person soap maker selling a few bars faces the same Responsible Person, Product Information File, and CPSR obligations as a large brand. There is no small-business exemption and no turnover threshold. The name and address of the Responsible Person must also appear on the product label, so this is not a filing you can keep out of sight.
How CIG covers it
What is included.
One mandate that puts a compliant Responsible Person in place and keeps your EU dossier current.
Reviewed by Cassandra Maddocks, chemist & biochemist · last reviewed 26 July 2026
An EU Responsible Person is the EU-established legal role every cosmetic product must name before it can be sold, under Article 4 of Regulation 1223/2009. CIG holds the role independently of any distributor, keeps your PIF at its address and manages CPNP notifications for $150 per product.
Legal basis: EUR-Lex: Regulation (EC) 1223/2009, CPNP (European Commission), EUR-Lex: GPSR (EU) 2023/988.
We act as your EU Responsible Person. Your products gain a compliant, EU-established Responsible Person without you setting up an EU entity. Our name and address go on the label for the EU market.
We hold your Product Information File and keep it complete and available to authorities. Under Article 11 it must stay on file for 10 years after the last batch of the product was placed on the market.
We put your CPSR in place, prepared by us and signed by a qualified safety assessor who holds a recognised diploma in pharmacy, toxicology, or medicine.
We notify your products through CPNP before they are placed on the market, and only after your confirmation. Once a product is notified in CPNP, no further national-level notification is needed within the EU.
We receive and handle authority correspondence on your behalf, act as your contact point for market surveillance, and keep your notifications current as your formulas, labels, or range change.
The documents
PIF, CPSR, and CPNP notification.
Three things sit behind an EU Responsible Person mandate. They are often confused, so here is what each one is and how it fits.
Product Information File (PIF)
The technical dossier the Responsible Person must hold for each product. Under Article 11 it contains a product description, the CPSR, the manufacturing method with a GMP statement to ISO 22716, proof of any claimed effect where justified, and data on animal testing. It is kept for 10 years after the last batch was placed on the market and must be available to authorities on request.
Cosmetic Product Safety Report (CPSR)
The safety report set out in Annex I, and part of the PIF. Part A gathers the safety information: composition, physico-chemical characteristics and stability, microbiological quality including challenge testing, impurities and packaging, exposure, and the toxicological profile. Part B is the assessment itself: the conclusion, any warnings, the reasoning including the Margin of Safety, and the assessor’s name, qualification, and signature.
CPNP notification
The notification of the product on the Cosmetic Product Notification Portal, required under Article 13 before the product is placed on the EU market. The portal itself is free to use, but only the appointed Responsible Person can submit. Notification requires the product name, category and function, the Responsible Person’s details, the full INCI formulation, label and packaging images, the CPSR reference, and manufacturing and batch information.
Who sees your CPNP data
CPNP data is made available only to competent authorities for market surveillance and to poison centres for medical treatment. Your full formula and product data are not visible to competitors or the public. Appointing a Responsible Person does not expose your formulation to anyone outside the authorities and the poison-centre network.
Who signs it
A qualified safety assessor signs every CPSR.
The Part B safety assessment cannot be signed by just anyone. It must be signed by an assessor who holds a university diploma in pharmacy, toxicology, medicine, or a similar discipline recognised by an EU Member State. This is the hard bottleneck in EU compliance, and it is why a safety report prepared in another format, such as a US safety report, does not transfer. The assessment has to be made and signed in the EU format by a qualified person.
We prepare the CPSR and a qualified assessor reviews the file and signs the conclusion. The safety conclusion is always made by a named, suitably qualified professional. Nothing is signed off on your behalf without that review, and no product is notified without a signed CPSR behind it.
What we need from you
The inputs that let us build your file.
The more complete your inputs, the faster your file moves. Most of this you will already hold from product development.
Full formula with INCI names and exact percentages. The quantitative and qualitative composition is the basis of the safety assessment, so it has to be exact, not approximate.
Manufacturing details and a GMP statement. The manufacturing method and confirmation of Good Manufacturing Practice to ISO 22716, plus the manufacturing country.
Stability and compatibility test data. Stability, packaging compatibility, and microbiological data including challenge (preservative efficacy) testing where relevant.
Label artwork and packaging images. The label text, warnings, and images of the packaging, which are needed for both the CPSR and the CPNP notification.
Claims and any supporting evidence. The claims you intend to make, with substantiation where a claimed effect needs to be justified.
Any existing safety data you already hold. Raw material safety data sheets, certificates of analysis, and any prior assessments. We tell you plainly what is usable and what still needs to be produced.
If some of this is missing, we will say so at the quote stage rather than after you have paid. Where lab testing is still needed, that testing sits outside the Responsible Person fee and takes its own time to complete.
Timelines
How long this takes.
Two clocks run at once: the paperwork clock, which we control, and the lab-testing clock, which the formula controls.
Appointing the Responsible Person
Once we have your inputs and the mandate is agreed, we can take up the Responsible Person role quickly. This is the fastest part of the process.
CPNP notification
With documentation ready, a CPNP notification typically takes 2 to 5 business days. Only the appointed Responsible Person can submit, so brands are advised to start 6 to 8 weeks before their planned launch.
Lab testing, when needed
If stability, challenge, or other testing is still outstanding, that is the long pole. Stability testing alone can run 3 to 12 months, so a new formulation can take months from a standing start rather than weeks.
The honest position is that the safety report and notification move on a scale of days to a few weeks when your data is ready. The end-to-end timeline is driven by whatever testing is still outstanding, which is why brands that start late miss their launch window. Tell us your target date and we will tell you what is realistic for your specific products.
Edge cases
Products that need extra steps.
Some products carry a higher assessment scope or a separate obligation. These are the ones to flag early.
Nanomaterials
A product containing nanomaterials needs a separate notification under Article 16, in addition to the standard CPNP notification. If any ingredient is present in nano form, tell us at the quote stage so we can scope both notifications.
Products for babies and children
Products intended for babies and young children carry a higher assessment scope. The exposure assumptions and the safety margins are different, so the safety assessment takes more work than a comparable adult product.
Higher-risk product types
Products such as hair dyes, permanent-wave products, and formulations with a long or complex ingredient list carry a heavier assessment. More ingredients and more restricted substances mean more toxicological work behind the CPSR.
Restricted and banned ingredients
The EU annexes list prohibited and restricted substances, and they change. An unauthorised ingredient is a common cause of recalls and market-surveillance action. We check your formula against the current annexes as part of the assessment and flag anything that needs to change before launch.
The bigger picture
Where the EU sits among your markets.
An EU Responsible Person covers the EU market only. It does not cover Great Britain, Switzerland, or the United States, and it does not cover Northern Ireland by default. Each of those is a separate regime with its own paperwork, and the portals do not talk to each other. A CPNP notification does nothing for the UK, and a Swiss address on the label does not transfer the legal obligation to Switzerland.
If you sell into more than one of these markets, we can cover them in one relationship rather than leaving you to stitch together separate providers. That keeps one set of source documents behind your EU, UK, Swiss, and US files.
Who it is for
Brands placing cosmetics on the EU market.
If you are an indie or growing beauty brand selling into the European Union, or planning to, and you are not established in the EU, the law requires a Responsible Person before your products can go on sale. This mandate is for brands that want that role covered properly, alongside the rest of their cross-border compliance.
The Responsible Person role is a continuous responsibility, not a one-time filing. It stays active for the whole time the product is on the market, which is why it runs as an ongoing mandate rather than a single setup fee. As your formulas, labels, or range change, the notifications and the file have to keep up, and that is part of what the mandate covers.
Pricing
Fixed, transparent pricing.
The EU and UK launch pack covers the safety report, Product Information File and notification for a product. Individual deliverables are also available.
Prices in USD, per product unless noted.
See full pricing →Where this service fits
The EU Responsible Person in your compliance path.
FAQ
Common questions.
Related
Pairs well with.
Sell in the EU
The full market overview of what the EU requires and how CIG covers it.
EU market →Safety assessment (CPSR)
The mandatory safety report, signed by a qualified assessor.
View service →Product Information File
The technical dossier the Responsible Person must hold.
View service →UK Responsible Person
Cover the British market in the same relationship.
View service →In practice
Compliance, in the real world.
