No EU Responsible Person
A non-EU address on the label, or no RP at all.
Your EU Responsible Person for cosmetics under Regulation (EC) No 1223/2009
Regulation (EC) No 1223/2009 applies to every cosmetic product placed on the EU market, whatever the sales channel. Marketplaces increasingly check that a listing has an EU Responsible Person before it goes live.
Offering a cosmetic product to consumers in the EU through a marketplace is making it available on the EU market. The product therefore needs a Responsible Person established in the EU, a Product Information File, a safety assessment, a CPNP notification and an EU-compliant label - exactly as in a physical shop.
Requirements and the exact documents requested change over time and differ between marketplaces. Always check the current seller requirements in your marketplace account before shipping stock.
A non-EU address on the label, or no RP at all.
No CPNP notification for the exact product and shade.
Listing images show a label without EU mandatory information.
Therapeutic claims can make the product a medicinal product instead.
A fulfilment service or logistics provider does not become your Responsible Person just by storing your goods. For an imported cosmetic product, the EU importer is the Responsible Person and may designate another person established in the EU by written mandate (Article 4(5)); that is how a non-EU brand usually appoints a professional Responsible Person. See who needs a Responsible Person.
No. The Cosmetics Regulation requires a Responsible Person established in the EU for every cosmetic product made available in the EU, including via marketplaces.
No. Marketplaces and fulfilment providers do not take on the Responsible Person role. It must be your EU importer or a Responsible Person you appoint in writing.
No. The CPNP notification covers the product in the Member States where it is placed on the market, regardless of the sales channel.
Check that each listed product has a Responsible Person, a PIF with a CPSR, a CPNP notification and a compliant label. Our free eligibility check starts with exactly this review.
What the notification contains and who submits it.
The label images in your listing must match these rules.
Most marketplace sellers of cosmetics ship from China.
Note: This guide provides general information about Regulation (EC) No 1223/2009, not legal advice. Specific obligations depend on your product and supply chain. Last reviewed 30 September 2026.
Tell us your product category and where your company is established. Before you sign a mandate, we tell you what the next step is.