Appointing a UK Responsible Person for cosmetics
Agree a written mandate and written acceptance, the exact products covered, confidential formula access, safety escalation and an exit handover. For imported cosmetics sold in Great Britain, the importer remains the Responsible Person without an accepted mandate. Coordinate factory documents through Cambridge China Bridge.
Get the appointment accepted in writing
For imported cosmetics placed on the Great Britain market, OPSS guidance says an importer can appoint an external Responsible Person through a written mandate. The appointee must be located in the UK and accept that mandate in writing. Without an accepted mandate, the importer is the Responsible Person.
Ask for a document identifying the importer, the appointed business, its UK address, the covered products and the effective date. Keep its written acceptance alongside the mandate. Agree what must be completed before the appointment starts. Our beauty sourcing guide covers the underlying launch paperwork.
Agree confidential access before sharing the formula
Agree who receives the full quantitative formula, how the factory sends it securely, who may access it and how revised versions reach the safety assessor and Responsible Person. Ask the provider to demonstrate how it will retrieve the supporting records, including when the usual contact is unavailable.
The Responsible Person must make the product information file readily accessible to a competent authority at the notified address. Draft confidentiality terms that permit necessary regulatory disclosure. Agree permitted uses, restrictions on onward sharing and record retention before disclosure. Use our IP protection guide for the wider supplier discussion.
Define products and services separately
Attach a product schedule recording brand, product name, formula version, fragrance or shade, packaging and factory. Define how additions and changes are submitted and accepted. Ask whether a changed formula, new claim or replacement factory triggers another review before supply.
Separately list the services purchased: file maintenance, safety assessment coordination, notification, artwork review and complaint handling. The Responsible Person remains responsible for ensuring compliance even where another specialist performs the work. Agree who supplies each document, who reviews it and how unresolved gaps are escalated.
Give safety escalation a working route
OPSS guidance requires corrective action, withdrawal or recall where the Responsible Person has reason to believe a product is non-compliant. Where it presents a risk to human health, the Responsible Person must immediately notify and cooperate with competent authorities. The Responsible Person or distributor must also report serious undesirable effects to the Secretary of State.
Agree emergency contacts, cover during absences, complaint forwarding and access to batch and customer records. Name who can stop dispatch, organise a withdrawal or recall and communicate with authorities. Agree how action proceeds during a dispute about costs. Use our imported product recall guide to prepare the operational response.
Plan termination before signing
Agree notice, termination triggers, handover charges and cooperation with a replacement provider. Include factory permission to transfer confidential records, file exports, complaint history, outstanding safety work and a review of labels and notification details. Ask what happens to stock already supplied and stock awaiting dispatch.
The product information file must be kept for ten years after the last batch was placed on the market. Specify who keeps those records and maintains authority access after termination. As a practical safeguard, coordinate the replacement's written acceptance and access before ending the existing appointment; avoid making handover depend on settling a disputed invoice.
Frequently asked questions
Is paying a Responsible Person enough to appoint them?
Obtain a written mandate and the provider's written acceptance. OPSS guidance says the importer remains the Responsible Person if no accepted mandate exists.
Can my factory send the formula directly to the provider?
Agree a secure direct route and confidentiality terms. Confirm that the assessor and Responsible Person can access the information needed, and that revised formulas follow the same route.
Does the appointment cover every product in my brand?
Define coverage in a product schedule. Include formula and packaging versions, and agree how new products, shades, fragrances and factory changes are reviewed and accepted.
What should happen when I change Responsible Person?
Agree replacement acceptance, confidential file transfer, complaint handover and review of labels and notification details. Specify who retains records and provides authority access after termination.