EU Cosmetics Compliance: How to Appoint an EU Responsible Person Under Regulation 1223/2009

Cosmetics products sold in the European Union are regulated under one of the most stringent consumer product safety frameworks in the world. Regulation (EC) No 1223/2009 governs every cosmetic product placed on the EU market — from mass-market skincare to artisan fragrances, from salon-grade haircare to independent makeup brands. At the centre of this regulation sits a mandatory requirement: every cosmetic product must have a designated EU Responsible Person.

For cosmetics brands based outside the EU — particularly those in the United Kingdom, United States, South Korea, and China — this requirement is the gateway to EU market access. Without a named EU Responsible Person, your cosmetics cannot legally be sold, distributed, or even stored for sale within any of the 27 EU member states. This guide covers exactly what Regulation 1223/2009 requires, what the EU Responsible Person role entails for cosmetics, and how Eldris delivers your appointment certificate in under one hour.

What Regulation 1223/2009 Requires

Regulation 1223/2009 establishes the legal framework for the safety of cosmetic products in the EU. It applies to any substance or mixture intended to be placed in contact with external parts of the human body or with the teeth and mucous membranes, for the purpose of cleaning, perfuming, changing appearance, protecting, or keeping in good condition. This covers skincare, haircare, colour cosmetics, fragrances, oral hygiene products, bath and shower products, and sun protection products, among others.

The regulation requires that every cosmetic product placed on the EU market has a designated Responsible Person. This person must be established within the EU. Their name and address must appear on the product packaging. And they must ensure that several specific obligations are met before the product reaches EU consumers.

The EU Responsible Person's Obligations for Cosmetics

Under Regulation 1223/2009, the EU Responsible Person has defined obligations. They must ensure that the cosmetic product has undergone a safety assessment by a qualified assessor, resulting in a Cosmetic Product Safety Report (CPSR) that forms part of the Product Information File (PIF). They must ensure that the PIF is established, maintained, and readily accessible to competent authorities at the address displayed on the packaging. They must ensure the product has been notified through the Cosmetic Product Notification Portal (CPNP) before being placed on the market. And they must cooperate with market surveillance authorities when requested.

This is where the distinction between what the EU Responsible Person ensures and what they physically do becomes critical. The Responsible Person ensures these obligations are met — they do not necessarily perform them. Your laboratory conducts the safety assessment and produces the CPSR. You or your regulatory consultant compile the PIF. The CPNP notification is filed by the Responsible Person or by the manufacturer or distributor as agreed. The Responsible Person's core function is to be the named EU contact who can present this documentation upon request.

What Eldris Does as Your Cosmetics EU Responsible Person

Eldris acts as your designated EU Responsible Person under Regulation 1223/2009 through EldrisAi OÜ, a registered entity based in Tallinn, Estonia (Reg. No: 3162734). In practical terms, this means Eldris provides the registered EU address that appears on your cosmetic product packaging. Eldris generates your official EU Responsible Person appointment certificate, typically within 60 minutes of completing the onboarding process. Eldris responds to market surveillance authority enquiries on your behalf, using template documentation and logged proofs. And Eldris maintains your compliance status through a centralised dashboard where you manage SKUs, update product details, and regenerate certificates at no additional cost.

Eldris does not produce your PIF. Eldris does not conduct your safety assessment. Eldris does not file your CPNP notification. Those are your responsibilities — or the responsibilities of your laboratory and regulatory consultants. Eldris is the named EU contact, not a full-service regulatory consultancy. This distinction keeps the service focused, the pricing low, and the turnaround time under one hour.

The PIF and CPNP — Your Responsibilities

Before appointing an EU Responsible Person, you need to understand what documentation you must have in place. The Product Information File (PIF) must contain a description of the cosmetic product, the Cosmetic Product Safety Report (CPSR), a description of the manufacturing method, evidence of the claimed effect where justified, and data on animal testing where applicable. The PIF must be kept at the EU address of the Responsible Person and made available to competent authorities upon request.

The CPNP notification must be submitted before the product is placed on the EU market. The notification includes product category, product name, the Responsible Person's details, the country of origin, the member states where the product will be sold, and the frame formulation or exact composition. This notification enables poison centres across the EU to provide appropriate treatment guidance in case of adverse reactions.

If you do not yet have a PIF or CPNP notification in place, you will need to arrange these before your products can legally be sold in the EU — regardless of whether you have an EU Responsible Person appointed. Eldris can be appointed in advance so that when your PIF and CPNP notification are ready, your EU contact is already active and your certificate is already in hand.

Packaging Requirements for Cosmetics

Regulation 1223/2009 requires specific information to appear on the packaging of cosmetic products sold in the EU. This includes the name and address of the EU Responsible Person, the country of origin for products imported from outside the EU, the nominal content at the time of packaging, the date of minimum durability or period after opening, the list of ingredients, and the product function if not obvious. The EU Responsible Person name and address that Eldris provides on your appointment certificate is the information that must appear on your packaging.

For Amazon sellers, this packaging requirement is particularly important. Amazon EU marketplaces require that the physical product received by the customer displays compliant packaging. Listings that show products without the required EU Responsible Person information on the packaging are subject to suppression.

Why Cosmetics Brands Choose Eldris

Cosmetics brands seeking EU market entry have traditionally relied on regulatory consultancies or law firms for EU Responsible Person appointment. These engagements typically involve detailed consultations about formulations, ingredient lists, and regulatory strategy — services that are valuable but separate from the core EURP appointment. The result is a bundled service with a bundled price tag, often running into thousands of pounds before a single product is listed.

Eldris unbundles the EU Responsible Person appointment from the broader regulatory consultancy. If you already have your PIF, your CPSR, and your CPNP notification handled by your laboratory or regulatory team, you do not need a full-service consultancy to appoint your EU Responsible Person. You need a registered EU entity to stand as your named contact. Eldris provides exactly that — in under one hour, for a one-time fee of £195 per country.

Pricing

One-time onboarding: £195 per country, paid once, for life. Monthly base fee: £9.95. SKU-based monthly tiers: up to 20 SKUs at £19.95, up to 50 at £39.95, up to 250 at £99.95, up to 500 at £149.95, up to 1,000 at £199.95, and up to 2,000 at £249.95 with unlimited compliance. Multiple cosmetics brands operate under a single country appointment.

Getting Started

If you have your PIF and CPNP notification ready, you can be fully compliant with an appointed EU Responsible Person in under one hour. If your PIF and CPNP are still in progress, appointing Eldris now means your EU contact is active the moment your documentation is complete — with zero delay at the final step. Either way, the Eldris onboarding process is the same: submit your product information, receive your certificate, and manage everything from the dashboard.