Cosmetovigilance – responsible person, distributor, manufacturer – how not to get confused?

EU regulations, specifically Regulation (EC) No 1223/2009 of the European Parliament and of the Council, introduce a maze of concepts, as they refer to manufacturers, importers, distributors and responsible persons. The distinction between these functions is important because, depending on the classification, EU regulations impose different obligations on individual entities. A manufacturer is a natural or legal person who manufactures a cosmetic product or has a cosmetic product designed or manufactured, and markets that product under their own name or trademark.

An importer is any natural or legal person established in the EU who places a cosmetic product from a third country, i.e. a country that is not a Member State of the EU, on the EU market. A distributor is any natural or legal person in the supply chain, other than the manufacturer or importer, who makes a cosmetic product available on the EU market.

In turn, only cosmetics for which there is a responsible person in the EU, i.e. a natural or legal person who is obliged to ensure that each cosmetic product placed on the market complies with the relevant legal requirements, are placed on the market.