As NI follows the EU Cosmetics Regulation, you may be classed as an importer or as a distributor under the UK Cosmetics Regulation.  Please check:

• If the brand’s RP is located in NI, they are the UK RP and you are likely to be identified as a distributor. As a distributor, you have obligations under Article 6 of the UK Cosmetics Regulation.  For more information, please check paragraphs 30-33 of the UK Government guidance for cosmetic products.
• If the brand’s RP is located in an EU/EEA country and have not appointed a UK RP, you are likely to be identified as an importer and therefore the UK RP. As such, you have full responsibility of the compliance of the cosmetic product in the UK.  For more information, please check the CTPA Guide ‘Supplying Cosmetic Products on the UK Market’.

If the brand’s RP is located in an EU/EEA country and have appointed a UK RP, you are likely to be classed as an importer.  However, you are strongly advised to liaise with the brand’s UK RP and arrange for a mandate, to shift your importer responsibilities to the designated RP.  In this way, you can be a distributor; as such, you have obligations under Article 6 of the UK Cosmetics Regulation.  For more information, please check paragraphs 30-33 of the UK Government guidance for cosmetic products.