AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
If you sell Nigerian shea butter in Ireland for use on skin or hair, it is a cosmetic product under EU Regulation 1223/2009 and the HPRA's rules apply whatever the size of your business. Each product needs a responsible person located in the EEA or Northern Ireland, a safety report signed off by a toxicologist or suitably qualified expert, a product information file, and notification on the EU's Cosmetic Product Notification Portal before it goes on sale. The label must carry the responsible person's name and EU address, Nigeria as country of origin, the ingredients and the other particulars in Article 19.
When shea butter becomes a cosmetic
Shea butter can be an ingredient, a food fat or a finished skin product. The rules turn on what you sell it as. Regulation 1223/2009 treats as a cosmetic any substance or mixture intended to be placed in contact with the external parts of the body, such as the skin, hair, nails and lips. A tub of raw or whipped shea sold to customers to rub on their skin, hair or a baby's body falls inside that.
The HPRA, which regulates cosmetics in Ireland, says the requirements apply to anyone making, importing from outside the EEA, distributing or retailing cosmetics here, and apply regardless of business size. A market stall or Instagram shop is not exempt. Bulk shea sold only to other manufacturers as a raw material is a different situation; if that is your model, confirm your position with the HPRA before you trade.
The responsible person
Every cosmetic placed on the EU market needs a responsible person, often called the RP. The HPRA's page on responsible persons says:
- An importer who brings cosmetics in from outside the EEA can be the RP for those products.
- The importer can instead mandate another entity in the EEA or Northern Ireland to act as RP, but the appointment must be accepted in writing by both parties.
- The RP must be located in the EEA or Northern Ireland. Your Nigerian supplier cannot be the RP from Nigeria.
- The product information file, the safety report and the CPNP notification must be in place before the product is placed on the market.
If you import shea butter under your own brand and sell it from Ireland, the most likely position is that you are the RP, with every obligation that brings. If you would rather another EEA business took the role, the written mandate has to be agreed by both sides before the product goes on sale.
What the responsible person must have
- Cosmetic Product Safety Report (CPSR)
- A safety assessment carried out by a toxicologist or suitably qualified expert, per the HPRA.
- Product Information File (PIF)
- Compiled and kept at the RP's address, and updated with new information such as undesirable effects or ingredient changes.
- CPNP notification
- Each product notified on the EU Cosmetic Product Notification Portal; updated if the formulation changes.
- Undesirable effects
- A system for recording and reporting serious undesirable effects after use.
- Claims
- Any claim, such as "heals eczema" or "organic", must be substantiated.
The HPRA's page also says cosmetics made in Ireland or elsewhere in the EEA must be made to Good Manufacturing Practice, citing EN ISO 22716:2007 or an equal or better standard, with documents to show it. For shea made in Nigeria, the safety assessor will still want to know how and where it was produced, so ask the producer for batch records, the source of the nuts, how the butter was extracted and filtered, and any test results. A rough, unrefined product made in a village cooperative can be sold, but only if the assessor is satisfied it is safe as you will present it.
Mixing in other ingredients
Adding fragrance, essential oils, cocoa butter or colour changes the formula, and each formula is a separate product needing its own safety report and notification. Some substances are restricted or banned outright in the annexes of the regulation. One example from a skin product: in June 2024 the UK's Office for Product Safety and Standards refused a lightening lotion at the border because it contained hydroquinone, which it called prohibited in cosmetic products under Regulation 1223/2009 as it applies in Great Britain. The same ingredient lists matter for any blended butter or cream you bring from Nigeria.
What the label must say
Article 19 of Regulation 1223/2009 lists the particulars on the container and packaging:
- The name or registered name and address of the responsible person, and for imported products the country of origin, so "Made in Nigeria" or equivalent.
- Nominal content by weight or volume, with limited exemptions for small packs and samples.
- Date of minimum durability, or, for products lasting over 30 months, a period after opening shown with the symbol in Annex VII.
- Particular precautions for use, including those set in the annexes.
- A batch number or other reference identifying the product.
- The product's function, unless clear from its presentation.
- A list of ingredients headed "ingredients", in descending order of weight.
Article 19(5) says the language for the content, durability date, precautions and function is set by the law of the member state where the product reaches the end user. The HPRA's page adds that the RP's European address must appear on each product.
Importing the stock
On the customs side, shea butter is an ordinary import. You need an EORI number (see how to get an EORI in Ireland), and you pay customs duty at the TARIC rate for its commodity code on value plus freight and insurance, then import VAT. Raw shea and a finished, packaged cream can fall under different codes, so classify what is actually in the shipment. Nigeria is a beneficiary of the EU's Standard GSP according to the GSP Hub (updated 15 October 2026), which may lower duty for goods of Nigerian origin with the right proof. The charges are explained in customs duty and VAT on goods from Nigeria.
Where Pryme fits
Producers and cooperatives in Nigeria usually want paying in naira. A Pryme Business Account holds euro and naira together, and Swap converts when you choose, with the rate and fee shown before you approve. A verifiable receipt for each supplier payment, produced with VerifyDoc.ai, is a tidy record to keep alongside the batch papers your safety assessor asks for. See business multicurrency accounts.
What to check first
- Are you selling shea for use on skin or hair? Then it is a cosmetic.
- Who is the RP, and is it in writing if not you?
- Is there a safety report for each formula?
- Is each product notified on the CPNP?
- Does the label carry all Article 19 particulars and "Made in Nigeria"?
Questions people ask
Do I need HPRA approval to sell shea butter in Ireland?
The HPRA does not describe a pre-approval. Instead each product needs a responsible person in the EEA or Northern Ireland, a safety report, a product information file and CPNP notification before sale.
Can I sell raw shea butter from Nigeria at a market in Ireland?
If you sell it for use on skin or hair, it is a cosmetic and the same rules apply, whatever your size. The HPRA says the requirements apply regardless of business size.
Who can be the responsible person for imported shea butter?
The importer can be, or the importer can mandate another entity located in the EEA or Northern Ireland, accepted in writing by both parties.
What must a shea butter label show in Ireland?
Under Article 19 of Regulation 1223/2009: RP name and address, country of origin for imports, content, durability date or period after opening, precautions, batch number, function if unclear, and the ingredients list.
Sources
- HPRA: Making, importing or selling cosmetic products in Ireland · accessed Oct 2026
- HPRA: The responsible person for cosmetic products · accessed Oct 2026
- Regulation (EC) No 1223/2009, Article 19, as adopted (legislation.gov.uk) · accessed Oct 2026
- GOV.UK OPSS product safety report 2406-0049c (19 Jun 2024) · accessed Oct 2026
- GSP Hub: Nigeria country information (last updated 15 Oct 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.