ERPA: the professional Responsible Person association
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It was founded in 2011, and has been recognized as an association by European authorities since 2013. The European cosmetics Responsible Person Association now establishes itself as an official interlocutor with one objective: giving the status of Responsible Person the dimension of a real profession, with a level of requirements that lives up to its responsibilities.
According to the text in Cosmetics Regulation 1223/2009, which introduced this concept into the cosmetics industry, the Responsible Person is mostly defined according to its obligations.
It is stated in Preamble 11 that 'In order to establish clear responsibilities, each cosmetic product should be linked to a responsible person established within the Community.'
Then, in Article 4 dedicated to this mission, it is specified that the Responsible Person 'shall ensure compliance with the relevant obligations set out in the Regulation.'
Responsible Persons are:
• The manufacturer established within the Community for a cosmetic product manufactured within the Community, and not subsequently exported and imported back
• Each importer for an imported cosmetic product he places on the market
• The distributor where he places a cosmetic product on the market under his name or trademark or modifies a product already placed on the market in such a way that compliance with the applicable requirements may be affected
From a gap to the association
However, nothing is mentioned in the Regulation about the competences or qualifications required to take on this function. This is a real regulatory gap, knowing how heavy all these obligations weigh on the Responsible Person. Indeed, ‘ensuring compliance with the obligations set out in ...