EU Responsible Person for Wet Wipes: Importer Duties

Short answer

Every cosmetic wet wipe sold in the EU needs a Responsible Person (RP) established in the EU. If you import wipes made outside the EU, you are the RP by default, unless you appoint another EU-based person in writing; a brand that places products under its own name also becomes the RP. The RP keeps the product information file (PIF) with the safety report, ensures GMP and labelling compliance, notifies the product on the CPNP before sale, and handles corrective action. Great Britain needs its own UK-based Responsible Person.

Who is the Responsible Person for imported wet wipes?

Article 4 of Regulation (EC) No 1223/2009 sets the rules (EUR-Lex):

Situation	Responsible Person
Wipes made in the EU	The EU manufacturer, unless it appoints someone in writing
Wipes made outside the EU, e.g. in China	The importer, for each product it imports, unless it appoints an EU-based person in writing
Non-EU manufacturer selling in the EU	Must designate an EU-established RP by written mandate
Distributor placing wipes under its own name or trademark, or modifying them	That distributor becomes the RP

For a private label brand importing from a Chinese supplier, that usually means the brand, its EU importer, or an RP service appointed in writing. Cosmetic wipes are in scope; disinfecting wipes follow biocide rules instead (see antibacterial vs disinfecting wipes).

What does the EU Responsible Person have to do?

Safety assessment (Article 10). A Cosmetic Product Safety Report (CPSR) by a qualified safety assessor, with a diploma in pharmacy, toxicology, medicine or a similar discipline.
Product information file (Article 11). Product description, CPSR, manufacturing method and a GMP statement, proof of claimed effects, and any animal testing data. Keep it for 10 years after the last batch is placed on the market, at the RP address on the label.
GMP (Article 8). Manufacture under good manufacturing practice; compliance with EN ISO 22716 gives a presumption of conformity.
CPNP notification (Article 13). Before sale, notify the product category, name, RP details, country of origin, Member State of placing on the market, frame formulation and other items, plus the original label.
Labelling (Article 19). RP name and address, country of origin for imported products, contents, durability date or PAO, precautions, batch number, function and ingredients list, in the languages each Member State requires.
Claims (Article 20). Claims must meet the common criteria in Regulation (EU) No 655/2013 and match PIF evidence (EUR-Lex).
Market duties (Article 5). Take corrective action, withdraw or recall non-compliant products, inform authorities of risks, and cooperate with them.

What is the CPNP and does it cost anything?

The Cosmetic Products Notification Portal is the EU’s online system for notifying cosmetics. The European Commission says notification is free of charge, and one notification covers the EU, so no separate national notification is needed (European Commission). The cost of being or hiring an RP lies in the safety assessment, the file and the ongoing responsibility, not in the portal.

Which documents should the RP get from the supplier?

Document	Used for
Full quantitative formula (INCI and %)	CPSR, CPNP frame formulation, label
Raw material specifications and safety data	CPSR
Microbiology and challenge test results	CPSR, PIF (see quality testing)
Stability data	Durability date or PAO (see shelf life)
Packaging specification	CPSR (packaging compatibility), PIF
GMP evidence, e.g. ISO 22716 certificate or audit	PIF GMP statement
Claim test reports	Proof of claimed effect

Some factories share full formulas only with the safety assessor under confidentiality. Agree this before ordering. Market-by-market requirements are in wet wipes regulations by market.

Do I also need a UK Responsible Person?

For Great Britain, yes. GOV.UK guidance says the UK Responsible Person must have an address in the UK where the PIF is kept (not a PO box or mail forwarding service), can be the manufacturer, importer, own-brand distributor or an appointed person, must keep the PIF in English for 10 years, and must notify the product to OPSS through the Submit Cosmetic Product Notification (SCPN) service before it is made available. Northern Ireland follows the EU route, so a product sold there needs an RP in Northern Ireland or the EU (GOV.UK).

What drives the cost of an RP service?

We do not quote third-party prices, but these factors usually decide the cost:

Number of SKUs and formulas (variants that share a formula may share parts of the work).
Whether the safety assessment and CPSR are included or supplied separately.
Complexity of claims and the testing needed to support them.
Number of label languages and markets (EU, GB, Northern Ireland).
Ongoing services: storing the PIF, handling authority requests, adverse event reports.

LX Wipe is a supplier, not an RP service. We collect the documents the partner factory can provide for your product so your RP or safety assessor can complete the file.

Plan the document pack before you order

Tell us your markets and SKUs. We confirm which formula, test and GMP documents the partner factory can provide for your RP or safety assessor before production.

Ask about documents Regulations by market

Frequently asked questions

Do I need an EU Responsible Person for wet wipes?

Yes, for cosmetic wet wipes placed on the EU market. Importers are the RP by default for products made outside the EU, unless they appoint an EU-based person in writing.

Is the CPNP notification free?

Yes. The European Commission states notification through the CPNP is free of charge and one notification covers the EU.

How long must the product information file be kept?

For 10 years after the last batch of the product was placed on the market, at the RP address shown on the label. The UK also requires 10 years.

Can a Chinese supplier be our EU Responsible Person?

Not from outside the EU. The RP must be established in the EU; a non-EU manufacturer must designate an EU-based RP by written mandate.

Does LX Wipe provide the documents for the PIF?

LX Wipe collects the documents the partner factory holds, such as formula, microbiology, challenge and stability data, for your RP or safety assessor. LX Wipe is not an RP service.

Sources

Regulatory information is a summary for buyers and is not legal advice. Check the official sources and your own compliance adviser before launch. Last reviewed 18 October 2026.