How to replace a cosmetics Responsible Person
Agree a written handover with a clear effective date and batch scope. Before ending the old arrangement, test access to retained files, settle notification and label changes, and name who handles earlier-batch complaints. Cambridge China Bridge can help coordinate factory records in China.
Agree the effective date and product scope
This guide covers replacement for the Great Britain market. For the launch requirements, use our beauty and personal care guide. A third party acting as Responsible Person must accept the manufacturer's or importer's written mandate in writing. Without an accepted mandate, the UK-established manufacturer or importer is the Responsible Person.
Prepare a handover schedule identifying each product, formulation, batch range and effective date. Distinguish products already supplied from factory stock, goods in transit and future production. Ask the incoming provider to confirm expressly whether its appointment covers earlier batches. As a practical safeguard, make termination of the outgoing service conditional on documented readiness.
Test access to retained files before termination
The product information file must be retained for ten years after the last batch was placed on the market and remain readily accessible to the competent authority at the notified address. Ending a service contract is therefore a poor point at which to discover that access has been disabled. See our cosmetics file and safety assessment guide for the underlying file requirements.
Agree who keeps the archive, who can retrieve it and how access continues after termination. Ask the incoming provider to open the actual files, including historical formulations, signed safety reports, test evidence, label versions and complaint records. Arrange confidential access to factory information where necessary. Keep an agreed file index and evidence that the handover was received.
Coordinate notification with the handover
OPSS statutory guidance says the Responsible Person must immediately update the Secretary of State electronically when required notification information changes. Put notification work into the handover schedule, including the Responsible Person details, file address and emergency contact. Our cosmetics notification guide explains the notification process.
Ask the incoming provider to confirm how it will handle the existing records in the notification service and what evidence it will give you. If the account or record arrangements are unclear, seek instructions from OPSS before closing the outgoing account. Keep copies of the previous and replacement records; do not assume a signed appointment changes the service records automatically.
Make a separate decision for old-labelled stock
The Responsible Person's name and address are required on both the container and outer packaging. Review the actual artwork alongside the agreed batch scope. For future production, approve the replacement details before printing and tell the factory which artwork to stop using.
For stock bearing the outgoing details, record where it is, whether it has already been supplied and whether the outgoing provider will remain contactable with file access. Ask the providers to document the appropriate treatment for each stock group, seeking Trading Standards advice where needed. Do not assume either blanket relabelling or unrestricted sell-through is the right answer simply because the service provider changes.
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Keep earlier-batch complaints connected
Agree who receives, investigates and forwards complaints about earlier batches, including complaints arriving at the address printed on old packs. Transfer open cases and retain the link between each complaint, batch, formulation and safety report. Name the person who contacts the factory and coordinates any corrective action. Our serious cosmetic reaction guide covers the response to serious harm.
OPSS guidance requires the Responsible Person or distributor to report serious undesirable effects, and requires corrective action where the Responsible Person has reason to believe a product is non-compliant. Treat the allocation of investigation work, costs and customer replies as a separate handover agreement. Do not treat it as proof that every earlier legal responsibility has transferred; obtain advice on disputed responsibility without delaying the safety response.
Frequently asked questions
When should the new cosmetics Responsible Person start?
Agree an effective date and product and batch scope in writing. Make the operational handover conditional on file access, notification arrangements, label decisions and complaint contacts being ready.
Can the old Responsible Person keep the product files?
Agree archive custody and continuing access expressly. The file must remain readily accessible to the competent authority at the notified address; test retrieval before ending the service.
Must I relabel all existing cosmetics stock?
Assess stock by batch, supply status and appointment scope. Ask the providers to document the appropriate label treatment and seek Trading Standards advice where needed before deciding on relabelling or continued supply.
Who handles complaints about earlier cosmetic batches?
Name an investigation lead and keep the old printed contact connected to it. Agree forwarding, records and costs expressly. Seek advice on disputed legal responsibility without delaying the safety response.