Over the past year, much of the compliance conversation in the UK has focused on packaging and Extended Producer Responsibility (EPR). But there is another regulatory requirement that continues to catch small cosmetic brands off guard - the Responsible Person obligation under UK and EU cosmetic law.
Unlike EPR, this is a market access requirement, not an environmental reporting exercise. If you place a cosmetic product on the market, you must comply, regardless of your size.
Under UK Cosmetics Regulation, every cosmetic product sold in the UK must have a formally appointed UK Responsible Person. If you sell into the EU, you must also appoint an EU-based Responsible Person under Regulation (EC) No 1223/2009. For brands operating across both markets, that means dual responsibility.
One of the biggest misconceptions we see among indie and early-stage brands is the belief that this only applies to larger manufacturers. It doesn’t. The law makes no distinction between a multinational beauty group and a small batch skincare start-up selling online.
Selling through platforms such as Etsy, Amazon or Shopify does not create an exemption. And neither does producing in small quantities. If a product meets the legal definition of a cosmetic and is placed on the market, a Responsible Person must be in place.
So what does that actually mean in practice?
The Responsible Person holds legal accountability for the product’s compliance. That includes:
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Maintaining the Product Information File (PIF)
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Ensuring a valid Cosmetic Product Safety Report (CPSR) is in place
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Submitting product notifications to the UK SCPN portal and/or EU CPNP portal
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Ensuring correct labelling (INCI ingredient listings, allergen declarations, batch codes, PAO symbols and warnings)
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Handling serious adverse event reporting
In practice, most small brands act as their own UK Responsible Person, which is perfectly acceptable provided the correct documentation and systems are in place.
The most common problems are when businesses skip formalities and we see structural gaps like a CPSR that was never formally commissioned, a Product Information File that exists in fragments rather than as a complete record, or an EU customer base without a formally appointed EU Responsible Person.
These issues often surface when a brand tries to scale, for example, when approaching retailers, entering marketplaces that request compliance documentation, or expanding into the EU. At that point, regulatory housekeeping becomes urgent rather than strategic.
For small producers, compliance is not complicated but it does require structure.
At a minimum, a UK-based brand should:
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Formally appoint a UK Responsible Person (which can be the company itself)
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Commission a CPSR for each formula
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Compile and maintain a Product Information File
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Notify products via the SCPN portal before placing them on the market
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Keep batch traceability records
None of this is particularly glamorous, and it rarely features in early-stage brand planning. Founders understandably focus on things like formulation, branding, packaging and marketing. But without regulatory compliance sitting underneath, growth becomes fragile.
As enforcement becomes more data-led and retailers become more cautious, gaps are increasingly likely to be identified. What once flew under the radar is now more visible.
The key takeaway is simply that Responsible Person obligations are not a “large company” issue. They are a legal prerequisite for selling cosmetics in the UK and EU. And for indie beauty brands and growing skincare businesses, understanding this early is far less costly than correcting it later. Compliance may not drive sales directly, but it protects everything you build.
