Do China imports need a UK Responsible Person?
The appointment depends on the product regime and your role. For medical devices, confirm the manufacturer's UK Responsible Person appointment arrangements with MHRA; for cosmetics, the importer is normally responsible unless another person is appointed. Buy compliance advice against a defined scope. Sourcing support is available from Cambridge China Bridge.
Start with the product and your role
Before comparing providers, write down the product, intended use, claims, brand owner and destination market. This guide concerns direct imports from China into Great Britain, meaning England, Scotland and Wales. Ask for a separate assessment for Northern Ireland. EU buyers follow EU rules. For small-scale selling, see our guide to small sellers and product safety.
Ask the provider to distinguish advice, testing, document preparation and a formal appointment in its proposal. A review of your paperwork should not be treated as acceptance of a representative role. Our markings and certification guide explains the evidence behind product markings.
Medical devices: the manufacturer appoints
For a medical device entering the Great Britain market, confirm with MHRA the appointment requirements for a manufacturer outside the UK. Importers and distributors do not themselves need to appoint a UK Responsible Person. As the importer, ask MHRA to confirm how to notify the manufacturer or its UK Responsible Person of your intention to import and who should provide your importer details to MHRA.
Ask the factory who its UK Responsible Person is and request confirmation that your exact device is covered. Agree how you will pass on complaints and obtain documents. If you also intend to take the representative role, request a separate scope for that work. The medical devices and PPE guide covers classification and registration.
Cosmetics: check who has accepted responsibility
For cosmetics imported from China into Great Britain, the importer is normally the Responsible Person unless a qualifying person is appointed. The Responsible Person needs a UK established address; a mail forwarding or PO box address does not qualify. If no accepted mandate exists, the importer remains the Responsible Person.
Ask for a written appointment and written acceptance covering the named products. Agree access to the formulation, responsibility for keeping the product information file current, and the process for approving changes. Confirm with OPSS the Responsible Person's duties concerning safety assessment and notification before sale. Our beauty and personal care guide explains those files rather than repeating them here.
Equipment: an authorised representative has a scope
Check the particular equipment regime rather than buying a generic representative service. For electrical equipment, manufacturers can appoint authorised representatives by written mandate to perform specified tasks. Ask which tasks the manufacturer proposes to delegate and whether the provider is accepting that exact scope.
HSE says importer responsibilities can also apply when you directly import new equipment for your own workplace. Keep purchase checks in your own process: inspect guards, match the declaration to the machine and check that English instructions describe the supplied configuration. Agree how installation concerns will be resolved before use. For machinery roles, see our guide to imported machine manufacturer responsibilities.
Working out your own order? Send us the product on WhatsApp and we reply the same working day: WhatsApp us
Buy advice against a clear deliverable
A compliance adviser may be the service you need when you want help identifying the regime, reviewing evidence or preparing an action list. Specify the output: a product-specific gap report, documents to obtain, artwork comments and unresolved questions. If a formal appointment is needed, ask for it expressly and separately. For chemical imports, see our GB substance notification guide. For residential fire doors, see our fire door import evidence guide.
Keep control of the specification, supplier changes, evidence collection and release decision. Agree who receives complaints, who contacts the factory and how records will be handed over if the provider changes. Cambridge China Bridge can coordinate factory evidence through its own staff in China; agree any specialist appointment separately.
Frequently asked questions
Does every China import need a UK Responsible Person?
Choose by product regime. Medical devices and cosmetics have different Responsible Person arrangements. For equipment, check the applicable regime and the proposed authorised representative’s scope.
Must I appoint a UK Responsible Person for medical devices?
Confirm with MHRA the appointment requirements for a manufacturer outside the UK. An importer does not need to appoint a UK Responsible Person separately, but should ask MHRA how to notify the manufacturer or its UK Responsible Person of its intention to import.
Can I pay an adviser instead of being the cosmetics Responsible Person?
Paying for advice is not enough to establish an appointment. Ask for written acceptance of the product scope. If no accepted mandate exists, the importer remains the Responsible Person.
Do importer duties apply to machinery for my own factory?
They can. HSE says importer responsibilities can also apply to users directly importing new equipment for their own workplace. Ask for a product-specific assessment before committing to the purchase.