Can block a launchEuropean UnionBeauty & personal care

Someone inside the EU has to own the product

A cosmetic product may be placed on the European Union market only where a legal or natural person established in the Union is designated as its responsible person, and for an imported product that person is the importer by default unless it designates someone else in the Union by written mandate accepted in writing.

A brand shipping into the EU from outside cannot be the responsible person itself, so the question is not whether to appoint one but whether its distributor becomes one by default and inherits the legal exposure along with the shelf space.

95 of a possible 97Tier A, primary document or measured outcome. Nothing at this tier is allowed past 97, however good it looks.

Verified August 5, 2026Rechecked every 365 days, next by August 5, 2027.

Constraint

Held since July 11, 2013A rule, law or policy that limits what you may do or say. The earliest date we are willing to say this held. It may well have been true before that; we do not backdate a record past the evidence we have read. Supported, version 1.

This entry is wrong if

The Regulation is amended to allow a non-EU manufacturer to act as its own responsible person, or Article 4 is repealed.

Written before the record was published, not after. If you can show this, send it to hello@tryorbt.com and the correction goes on the record with the entry.

Evidence

Tier Aregulation
Publications Office of the European Union: Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products
Only cosmetic products for which a legal or natural person is designated within the Community as ‘responsible person’ shall be placed on the market.
Read 2026-08-05 · Open government · page hash 858298b0649b
Tier Aregulation
Publications Office of the European Union: Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products
For an imported cosmetic product, each importer shall be the responsible person for the specific cosmetic product he places on the market. The importer may, by written mandate, designate a person established within the Community as the responsible person who shall accept in writing.
The default assignment to the importer is the operative half for a brand entering from outside the Union, and it is the half that is usually discovered after a distributor agreement is signed rather than before.
Read 2026-08-05 · Open government · page hash 858298b0649b

History

v1createdAugust 5, 2026
Initial entry from primary regulator text outside the United States, read 2026-08-05. EUR-Lex is behind a bot challenge we do not work around, so this text comes from the Publications Office Cellar service under content negotiation, which is the documented machine-readable route to the same Official Journal document.

Append-only. Nothing in this list is edited or removed once written, including the entries that record our own mistakes. Every change to every record is on the corrections page, and the same log is in entries.json under revisions.

eu
market-entry
compliance
importer
responsible-person
beauty

Cite this entry

“Someone inside the EU has to own the product”, The Orbt Market Index 0.1.0, entry omr:eu:an-importer-is-the-responsible-person, retrieved September 9, 2026, https://tryorbt.com/markets/entry/eu--an-importer-is-the-responsible-person. Dataset: https://doi.org/10.5281/zenodo.22679129

Orbt, "Someone inside the EU has to own the product," Orbt Market Index, entry omr:eu:an-importer-is-the-responsible-person, verified August 5, 2026, https://tryorbt.com/markets/entry/eu--an-importer-is-the-responsible-person.

@misc{orbt-eu-an-importer-is-the-responsible-person,
  title        = {Someone inside the EU has to own the product},
  author       = {{Orbt}},
  year         = {2026},
  doi          = {10.5281/zenodo.22679129},
  note         = {The Orbt Market Index 0.1.0 (dataset DOI 10.5281/zenodo.22679129), entry omr:eu:an-importer-is-the-responsible-person. Verified 2026-08-05},
  howpublished = {\url{https://tryorbt.com/markets/entry/eu--an-importer-is-the-responsible-person}},
  license      = {Orbt Index Public Licence. Free to quote and cite; not to redistribute}
}

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