Under the EU Cosmetics Regulation you are classed as a distributor.
A distributor is “any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a cosmetic product available on the Community Market”. This includes wholesalers, retailers, shops, beauty or hair salons, telesales, outlets and internet selling etc.
Distributors are not usually the Responsible Person for the product but they do have specific obligations established under Article 6 of the EU Cosmetics Regulation.
Distributors should provide consumers with safe products. To achieve this, they are required to:
- verify or check some elements of the labelling,
- take appropriate measures in certain situations, and
- communicate with Competent Authorities and the Responsible Persons.
Distributors are not required to assess the safety of cosmetics by checking or asking to see the Product Information File (PIF).
The obligations of distributors under the EU Cosmetics Regulation are outlined in the CTPA Guide to Supplying Cosmetic Products on the UK Market. Further detail and guidance can also be found in the CTPA Distributor Guide (Distributors Roles and Responsibilities under the EU Cosmetics Regulations).