EU Responsible Person for Fragrances and Cosmetics
What brand owners must have in place before selling in the EU
If you plan to sell fragrances, perfumes, body oils, or other cosmetic products in the European Union, appointing an EU Responsible Person is mandatory. This role is often misunderstood. Many brand owners assume that having Safety Data Sheets (SDS) or manufacturing in Europe is sufficient. Under EU law, it is not.
This article explains what the EU Responsible Person does, what is required before cosmetics can be placed on the EU market, and where the Responsible Person’s responsibilities begin and end. It also clarifies how SDS and CLP fit into the picture, and what EaseCert can and cannot do.
1. Are fragrances considered cosmetic products in the EU?
Yes. Alcohol-based fine fragrances, including Eau de Parfum, Extrait de Parfum, Parfum, and similar products, are classified as cosmetic products under European Regulation (EC) No 1223/2009.
1.1 What the cosmetics regulation covers
Under EU law, cosmetics include any substance or mixture intended to be applied to the external parts of the human body (such as skin, hair, nails, lips, or external intimate areas) or to teeth and the mucous membranes of the oral cavity, mainly for one or more of the following purposes: Perfuming, changing appearance, protecting, keeping in good condition, and correcting body odours.
Fragrances and cosmetic products belong to the Cosmetic Products (Personal Care & Beauty Products) group under EU law.
This group is defined and regulated by Regulation (EC) No 1223/2009 on Cosmetic Products, which applies to all products intended to be applied to the external parts of the human body or to the teeth or oral mucosa for cosmetic purposes.
1.2 What this product group includes
The cosmetic products group includes, but is not limited to:
Fragrances and perfumes (Eau de Parfum, Extrait de Parfum, Parfum), body oils and massage oils, skincare products such as creams, lotions, and serums, hair and scalp products, decorative cosmetics and makeup, and non-medicated personal hygiene products.
1.3 Regulatory clarification
Fragrances are not treated as a standalone regulatory category in EU legislation. They are a subcategory of cosmetic products, even though they may also involve chemical legislation at the supply-chain level, such as CLP classification and Safety Data Sheets for alcohol-based mixtures.
1.4 Why this classification matters
Because fragrances fall under the cosmetic products group, they follow the cosmetics compliance pathway rather than the General Product Safety Regulation (GPSR). This means compliance is based on cosmetic-specific requirements such as a Cosmetic Product Safety Report (CPSR), a Product Information File (PIF), CPNP notification, and appointment of an EU Responsible Person.
Understanding this higher-level product grouping is essential, as it determines which legal framework applies, which documents are required, and which authorities have oversight.
If you place the product on the EU market under your brand name, you take responsibility for compliance (even if a third-party manufacturer created the formula and produced the finished goods).
2. What does “placing a cosmetic product on the EU market” mean?
“Placing on the market” is broader than many brand owners expect. It generally means making a product available for distribution, consumption, or use in the EU in the course of a commercial activity, whether in return for payment or free of charge.
2.1 Sales channels that count as placing on the EU market
Examples include:
DTC webshops that ship to EU consumers, sales through marketplaces (see Amazon EU sales compliance), sales through distributors, wholesalers, or selective boutiques, and promotional distribution (if it is part of a commercial strategy).
2.2 One portfolio, multiple obligations
If you sell multiple SKUs, each product must have its own safety assessment and documentation. The Responsible Person must also be clearly linked to each product and its documentation set.
3. What is an EU Responsible Person?
The EU Responsible Person (EURP) is the legal entity established in the European Union that takes regulatory responsibility for a cosmetic product under Regulation (EC) No 1223/2009.
3.1 Why the Responsible Person is mandatory
Without an appointed Responsible Person, a cosmetic product cannot legally be sold in the EU. Authorities and market surveillance bodies need an EU-based entity responsible for compliance, documentation availability, and post-market actions if safety issues arise (see why an EU Responsible Person is required).
3.2 Where the Responsible Person must appear
The Responsible Person’s name and address must appear on the product label (see EU labelling requirements). In addition, the Responsible Person must be able to provide the Product Information File (PIF) promptly upon request by authorities.
4. The EU Responsible Person is only one part of cosmetics compliance
Appointing an EU Responsible Person does not replace the need for full cosmetics compliance. Before a fragrance or cosmetic product can be legally placed on the EU market, the following must be in place for each product.
4.1 Cosmetic Product Safety Report (CPSR)
A CPSR is mandatory for every cosmetic product sold in the EU. It must be prepared and signed by a qualified cosmetic safety assessor (commonly a toxicologist) who meets the legal qualification requirements under the cosmetics regulation.
4.1.1 What the CPSR evaluates
The CPSR assesses consumer safety under normal and reasonably foreseeable conditions of use. It typically covers:
Ingredient review and toxicological profiles, exposure calculations, margins of safety, impurities and stability considerations, microbiological quality where relevant, intended use and target consumer groups, foreseeable misuse where applicable, and overall safety conclusion.
4.1.2 SDS is helpful, but it is not a CPSR
An SDS is a chemical workplace and supply chain document and is not a replacement for a CPSR. For cosmetics, safety assessment focuses on consumer exposure through intended cosmetic use, which is different from occupational or chemical hazard classification.
4.2 Product Information File (PIF)
Each cosmetic product must have a complete Product Information File (PIF). The PIF must be kept available at the Responsible Person’s EU address and provided to authorities upon request (see technical file and documentation guidance).
4.3 CPNP notification
Every cosmetic product must be notified in the Cosmetic Products Notification Portal (CPNP) before it is sold in the EU.
5. The role of CLP Regulation and SDS for fragrances
Finished cosmetic products are regulated primarily under Regulation (EC) No 1223/2009. However, the Classification, Labelling and Packaging Regulation (EC) No 1272/2008 (CLP) still plays an important supporting role for substances and mixtures in the supply chain.
Learn more in the EaseCert article on CLP Regulation (EC) No 1272/2008.
6. What EaseCert does as EU Responsible Person
EaseCert supports brand owners by acting as the EU Responsible Person once all mandatory documentation is in place. An overview of services is available under What We Offer. A detailed overview of eligibility, service scope, and onboarding requirements is available here: Personal Care & Beauty Products, EU Responsible Person Service
7. What EaseCert does not do
To avoid confusion, it is important to be clear about service boundaries.
8. How many SKUs can be covered?
Grouping principles follow a risk-based documentation approach similar to the GPSR risk analysis process.
9. Typical onboarding timeline
Once all required documents are available and complete, onboarding typically takes 5 to 10 working days.
10. Practical compliance sequence for fragrance and cosmetics brands
For broader context on EU product compliance, see the EU product launch checklist and the EU compliance guide for consumer products.
Frequently Asked Questions
Do fragrance and perfume products require an EU Responsible Person?
Yes. All cosmetic products placed on the EU market, including alcohol-based fragrances and perfumes, must have an EU Responsible Person established in the European Union. This requirement applies regardless of where the product is manufactured and whether it is sold online or through physical retail channels.
Is an SDS sufficient to sell fragrances in the EU?
No. A Safety Data Sheet is a chemical supply chain document prepared under the CLP Regulation and does not replace a Cosmetic Product Safety Report (CPSR). For EU market access, a CPSR and a complete Product Information File are mandatory.
What is the difference between a CPSR and an SDS?
An SDS focuses on chemical hazard classification, workplace handling, storage, and transport safety. A CPSR evaluates consumer safety under normal and foreseeable cosmetic use, including exposure calculations and toxicological assessment. Both may exist for the same product, but they serve different regulatory purposes.
Do I need a separate CPSR for each fragrance SKU?
Yes. Each cosmetic product requires its own CPSR. Even when fragrances are part of the same brand or collection, differences in formulation or concentration typically require individual safety assessments.
Can multiple fragrances be covered under one EU Responsible Person service?
Yes, in many cases multiple fragrance SKUs can be managed under a single EU Responsible Person appointment when they form a coherent product family. This does not remove the requirement for individual CPSRs, PIFs, and CPNP notifications per product.
Does manufacturing in France or another EU country remove the need for an EU Responsible Person?
No. Even if a fragrance is manufactured in an EU Member State, an EU Responsible Person must still be formally designated for the finished product placed on the market under your brand name.
Does EaseCert prepare CPSRs or submit CPNP notifications?
No. EaseCert does not prepare Cosmetic Product Safety Reports, submit CPNP notifications, or compile Product Information Files. These elements must be arranged through qualified third parties. EaseCert acts as EU Responsible Person once all mandatory documentation is complete.
How long does it take to appoint an EU Responsible Person?
Once all required documents are complete and available, EU Responsible Person onboarding typically takes 5 to 10 working days. Delays usually occur when CPSRs, PIFs, or labeling elements are incomplete or inconsistent.
Where must the Product Information File be kept?
The Product Information File must be kept available at the EU Responsible Person’s address and provided to EU authorities upon request without delay.
What happens if I sell fragrances in the EU without an EU Responsible Person?
Selling cosmetic products without an EU Responsible Person is a regulatory violation. Authorities may order product withdrawals, sales bans, recalls, and impose penalties. Marketplaces may also remove non-compliant listings.
11. References and official sources
- Regulation (EC) No 1223/2009 on Cosmetic Products (EUR-Lex)
- Regulation (EC) No 1272/2008 (CLP) (EUR-Lex)
- Cosmetic Products Notification Portal (CPNP), European Commission
- EU Cosmetics Framework, European Commission
For further questions, see the EaseCert FAQ or contact EaseCert directly.