The ‘Responsible Person’ explained | A complete guide for beauty brands
There’s lots to get to grips with when it comes to cosmetic regulations and labelling requirements for personal care products. It can sometimes feel a little overwhelming for first-time brands. But, Hera Beauty is on hand to help make the process as streamlined as possible, supporting you every step of the way.
In this industry insight, we’ll explain exactly what the role of ‘Responsible Person’ or ‘RP’ is, and what it means for private label manufacturing. Understanding what this role entails and who is responsible for it is essential to ensure compliance. As your manufacturing partner, we aim to help you through the process and can supply supporting documentation to help launch your beauty range to market in a smooth and stress-free way.
What is the ‘Responsible Person’?
Firstly, it’s important to understand that, under UK Cosmetics Regulations, the Responsible Person is a legally designated individual or company that takes full regulatory responsibility for a cosmetic product before it is placed on the market. This legislation is in place to ensure the very highest standards of consumer safety at all times, and it covers all beauty products - whether sold or given away as free samples - that are available to the public.
In short, the Responsible Person is the legal guardian of the product. So, what does this mean? They must:
● Ensure the product complies with all UK cosmetic legislation.
● Hold and maintain the Product Information File (PIF). This must be kept for 10 years after the last batch of the cosmetic product was made available.
● Receive a valid Cosmetic Product Safety Report (CPSR), conducted by a qualified assessor.
● Register the product with the Office for Product Safety and Standards (OPSS) in the UK and/or EU Cosmetic Product Notification (CPNP).
● Verify that labelling and claims are correct (including INCI ingredients, warnings, batch number, and shelf life). Read more about beauty product labelling here.
● Make sure the product is presented in a way so that it isn’t mistaken for food, has clear labelling, and instructions on use and disposal.
● Ensure ISO 22716 GMP compliance. This is because the manufacture of cosmetic products must comply with ‘good manufacturing practice’ standards.
● Manage adverse reaction reporting and product recalls.
● Act as the main point of contact for Trading Standards and the Office for Product Safety and Standards (OPSS).
● Be named on the label with a UK address for UK distribution, an EU address for European distribution, and so on.
What is the Product Information File (PIF)?
For beauty products, this is a mandatory file of documents containing a product description, safety assessment, ingredient list, manufacturing information, labelling and packaging, microbiological data, animal testing statement, and scientific evidence for any marketing claims. Ultimately, the PIF proves a product is compliant and safe for consumers. At Hera Beauty, we can provide (on request) a PIF summary for all of our natural pre-approved formulations, which you can launch quickly under your brand name. If you need a separate
Cosmetic Product Safety Report (CPSR), then this can also be purchased.
Who is the ‘Responsible Person’?
So, who can be named as the RP? The law focuses on who places the product on the market under their name, not who physically made it. So, it’s typically you, the brand owner, who carries the legal responsibility for bringing the beauty formulation to market. Another option for the choice of RP exists, which is to appoint a third-party regulatory consultancy that specialises in compliance.
It’s not a role to be undertaken lightly. The person or company named is the legal liability holder, which means that if anything goes wrong (such as launching an unsafe product, making incorrect claims, or other forms of non-compliance), then authorities can fine you, which also has the potential to cause reputational damage to your brand.
Partner with Hera Beauty
This means it’s important to work with a manufacturer who has extensive knowledge and expertise in launching personal care brands. As a leading private label manufacturer in the UK, Hera Beauty formulates products to the highest possible standards of consumer safety. Our Peterborough facility is GMP-certified, and we can provide the technical documentation needed to support our partners in their role as RP.
Whether you want full product development, contract manufacturing, or private label formulations, our technical and quality control team members monitor every step of the journey. If you have any questions, we are happy to advise - just ask one of our experts.
