What is an EU Authorized Representative (EU AR)?

An EU Authorized Representative (EU AR) is a legally designated entity based in the European Union that acts on behalf of a non-EU manufacturer or seller. Under the General Product Safety Regulation (GPSR), every non-EU seller of physical products must have an EU AR whose name and contact details appear on product labels and marketplace listings such as Amazon, Etsy, and Shopify.

Do Amazon sellers need an EU Authorized Representative?

Yes. Amazon requires all non-EU sellers to provide EU Responsible Person (EU Authorized Representative) details for products sold on EU marketplaces including Amazon.de, Amazon.fr, Amazon.it, Amazon.es, and others. Failure to comply results in listing deactivation. This requirement is mandatory under GPSR (EU 2023/988), effective December 13, 2024.

What is a Digital Product Passport (DPP)?

A Digital Product Passport (DPP) is a digital record containing information about a product's materials, components, repairability, sustainability data, and certifications. Under EU Regulation 2024/1781 (ESPR — Ecodesign for Sustainable Products Regulation), DPPs will be mandatory for batteries from February 2027, and for textiles, electronics, and other categories in subsequent years.

What is GPSR and when did it come into effect?

GPSR stands for General Product Safety Regulation (EU 2023/988). It replaced the older General Product Safety Directive and came into full effect on December 13, 2024. It applies to all physical consumer products sold in the EU, including products sold through online marketplaces by non-EU sellers.

When is the battery passport mandatory in the EU?

Battery passports become mandatory in the EU from February 18, 2027, under EU Battery Regulation 2023/1542. All industrial batteries, EV batteries, and LMT batteries above 2 kWh placed on the EU market must have a Digital Product Passport (DPP) accessible via a QR code.

Do Etsy sellers need an EU Authorized Representative?

Yes. Non-EU Etsy sellers who ship physical products to EU buyers are subject to GPSR and must designate an EU Authorized Representative (EU Responsible Person). This applies to all product categories covered by GPSR, including handmade goods, toys, electronics, cosmetics, and clothing accessories.

What is the difference between a GPSR Responsible Person and an EU Authorized Representative?

A GPSR Responsible Person under Regulation (EU) 2023/988 and an EU Authorised Representative are distinct legal concepts. Under GPSR, the applicable role is the Responsible Person. Some marketplaces may use different terminology in their interfaces, but this does not make the legal roles equivalent.

Can I sell cosmetics on Etsy EU without a Responsible Person?

No. Under EU Cosmetics Regulation 1223/2009, every cosmetic product sold to EU customers must have a Responsible Person established in the EU.

Do I need to register each cosmetic product separately?

Yes. Each cosmetic product must be individually notified in the CPNP before it can be sold in the EU. AuraDPP includes CPNP notification support.

Cosmetics Responsible Person EU: What Non-EU Sellers Need to Know

Updated: July 2026. If you sell cosmetics, skincare, haircare, makeup, or personal care products to EU customers from outside the EU, you are subject to the EU Cosmetics Regulation (EC No 1223/2009). This regulation requires that every cosmetic product placed on the EU market has a Responsible Person established in the EU. This guide explains the specific requirements for cosmetics, how the Cosmetics Responsible Person differs from the GPSR Responsible Person, and what non-EU sellers on Amazon, Etsy, and Shopify need to do.

What Is the Cosmetics Responsible Person?

Under Article 4 of EU Cosmetics Regulation 1223/2009, only a Responsible Person established in the EU may place a cosmetic product on the EU market. The Responsible Person is legally responsible for the product's compliance with the Cosmetics Regulation, including the Product Information File (PIF), safety assessment, labelling, and notification in the Cosmetic Products Notification Portal (CPNP). For non-EU sellers, this means appointing an EU-established entity as Responsible Person before selling cosmetics to EU customers.

Cosmetics Responsible Person vs. GPSR Responsible Person

These are two separate legal roles under two different EU regulations. The GPSR Responsible Person (under EU 2023/988) covers general product safety for all consumer products including cosmetics. The Cosmetics Responsible Person (under EC 1223/2009) is specific to cosmetics and covers the product information file, safety assessment, CPNP notification, and labelling compliance. Non-EU cosmetics sellers need both. AuraDPP provides both roles in a single subscription.

Role	Regulation	Covers	Required for Cosmetics
GPSR Responsible Person	EU 2023/988	General product safety	✓ Yes
Cosmetics Responsible Person	EC 1223/2009	Cosmetics-specific compliance (PIF, CPNP, safety)	✓ Yes

What Does the Cosmetics Responsible Person Do?

The Cosmetics Responsible Person has several specific obligations under EC 1223/2009: (1) Product Information File (PIF) — maintain a PIF for each product containing the product description, cosmetic product safety report, manufacturing method, safety assessment, and evidence of claimed effects; (2) CPNP Notification — notify each cosmetic product in the EU Cosmetic Products Notification Portal before placing it on the market; (3) Labelling compliance — ensure all products are labelled in the language(s) of the EU member states where they are sold, including the Responsible Person's name and address; (4) Serious Undesirable Effects (SUE) reporting — report any serious undesirable effects to competent authorities; (5) Market surveillance cooperation — cooperate with EU authorities during inspections.

Which Products Are Covered?

The EU Cosmetics Regulation covers any substance or mixture intended to be applied to the external parts of the human body (skin, hair, nails, lips, external genital organs) or to the teeth and mucous membranes of the oral cavity, with the exclusive or main intention of cleaning, perfuming, changing appearance, protecting, keeping in good condition, or correcting body odours.

Product Type	Covered
Skincare (moisturisers, serums, sunscreen)	✓ Yes
Makeup (foundation, lipstick, mascara)	✓ Yes
Haircare (shampoo, conditioner, hair dye)	✓ Yes
Perfumes and fragrances	✓ Yes
Nail products	✓ Yes
Toothpaste and mouthwash	✓ Yes
Soap and shower gel	✓ Yes
Dietary supplements (taken orally)	✗ No — food law applies
Medicated creams (prescription)	✗ No — pharmaceutical law applies

Cosmetics on Amazon EU: What Amazon Requires

Amazon EU requires cosmetics sellers to provide the name and EU address of the Responsible Person for each cosmetic product listing. Without a valid EU Responsible Person, Amazon may restrict or remove cosmetics listings on Amazon.de, Amazon.fr, Amazon.it, Amazon.es, and other EU marketplaces. AuraDPP provides the Responsible Person service and issues the required appointment documentation within 24 hours of receiving complete documentation.

Frequently Asked Questions: Cosmetics Responsible Person

Can I sell cosmetics on Etsy EU without a Responsible Person?: No. Under EU Cosmetics Regulation 1223/2009, every cosmetic product sold to EU customers must have a Responsible Person established in the EU. This applies regardless of the platform — Etsy, Amazon, Shopify, or your own website. Etsy has started enforcing this requirement and may remove non-compliant listings.
Do I need to register each cosmetic product separately?: Yes. Each cosmetic product must be individually notified in the CPNP (Cosmetic Products Notification Portal) before it can be sold in the EU. The Responsible Person handles this notification on your behalf. AuraDPP includes CPNP notification support in the cosmetics compliance service.
What is a Product Information File (PIF) and do I need one?: Yes, a PIF is mandatory for every cosmetic product sold in the EU. The PIF must include the product description, safety assessment, manufacturing method, and evidence of claimed effects. The Responsible Person must keep the PIF available for EU authorities for 10 years after the last batch of the product is placed on the market.
Is sunscreen a cosmetic or a medicine in the EU?: In the EU, most sunscreens are classified as cosmetics under EC 1223/2009 (not medicines), provided they make only cosmetic claims (protection from UV). Sunscreens with SPF 50+ or medical claims may be subject to additional requirements. AuraDPP can advise on the classification of your specific products.

Check your cosmetics compliance with the free GPSR Compliance Checker or contact AuraDPP for a full cosmetics compliance assessment. — Goran Matejic, LIMASE s.r.o. (AuraDPP), Bratislava, Slovakia | EU Cosmetics Regulation 1223/2009 (EUR-Lex)