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
Every cosmetic product sold to consumers in Great Britain must have a Responsible Person established in the UK, with a UK address that is not a PO box or mail-forwarding address. If you import a Nigerian cosmetic and sell it, you are usually that person by default, and you carry the duty to hold a Product Information File with a safety report from a qualified assessor before the product goes on sale.
Nigerian body butters, black soaps, hair oils and skin creams sell well in the UK, and many importers start by buying a few cartons from a supplier in Lagos or Aba and listing them online. The legal question that catches most of them is not customs duty but this one: who is the Responsible Person for each product? The answer decides who gets the letter from Trading Standards if something goes wrong.
What the Responsible Person is
Guidance from the Office for Product Safety and Standards (OPSS), updated 16 October 2026, says a cosmetic product can only be made available to consumers in Great Britain if a Responsible Person is designated for it. That person can be a business or an individual, including a sole trader. They must be established in the UK and give a UK address on the label; a mail-forwarding service or PO box does not count.
The guidance lists who can take the role:
- the manufacturer, if it is established in the UK
- the importer, meaning the UK business that first places a product from outside the UK on the GB market
- a distributor that puts the product out under its own name or brand
- a person appointed in writing by the manufacturer or importer to act for them
For goods made in Nigeria the manufacturer is outside the UK, so it cannot be the Responsible Person itself. Under the GB version of the Cosmetics Regulation, the importer is the business established in the UK that places a product from outside the UK on the market. If that is you and nobody else has been appointed, the role falls to you.
What the Responsible Person must hold and do
The role is not a name on a label. According to the OPSS page, the Responsible Person must:
- Keep a Product Information File (PIF) in English for each product, held for 10 years after the last batch is placed on the market. It includes a product description, the cosmetic product safety report, evidence of good manufacturing practice (ISO 22716 is the example given) and proof of any claims made.
- Make sure a safety assessment has been carried out by a qualified safety assessor, someone with a qualification in pharmacy, toxicology, medicine or a similar discipline. The report has a Part A (safety information) and a Part B (the assessor's conclusion).
- Notify the product to OPSS through the Submit cosmetic product notifications service before it is made available.
- Report serious undesirable effects to OPSS.
- Check the label: Responsible Person name and address, country of origin for imported products, contents by weight or volume, date of minimum durability or period after opening, precautions, batch number, function and ingredients.
Ingredients must also comply with the GB lists of banned and restricted substances and the positive lists for colourants, preservatives and UV filters. OPSS published a product safety report on 19 June 2024 about a skin lightening lotion refused at the border and destroyed because it contained hydroquinone, which is prohibited in cosmetic products. Our guide to banned ingredients in skin lightening products covers that risk in detail.
Three ways importers set this up
| Set-up | Who is the Responsible Person | What to watch |
|---|---|---|
| You import and sell under the Nigerian brand | You, as importer | You need the safety report and PIF; ask the Nigerian maker for full formulation and manufacturing records before you order |
| You sell under your own UK brand | You, as the distributor whose name is on it | Same duties; your claims on the label must be backed in the PIF |
| The Nigerian brand appoints a UK company | The appointed company, by written mandate | Get a copy of the mandate and confirm the product is notified in that company's name |
Some UK firms sell Responsible Person services to overseas brands. OPSS does not publish their prices, so compare written quotes and check the mandate states which products it covers.
Worked example: one shea body butter
Example. Ada runs a small online shop in Manchester and wants to sell a whipped shea body butter made by a small producer in Enugu. Before listing it she:
- asks the producer for the full ingredient list with percentages, the batch records and a description of how it is made;
- pays a qualified safety assessor to review the formula and write the safety report;
- puts her company name and UK trading address on the label, with "Made in Nigeria" and the batch number;
- builds the PIF and notifies the product on the OPSS service;
- only then lists it for sale.
If the producer will not share the formula, Ada cannot complete a safety assessment, and the product should not be sold. That single conversation with the supplier is often where the decision is made. The sister article on SCPN notification explains the notification step itself.
What to check first
- Is the product a cosmetic at all? Raw shea or unrefined oils sold in bulk to manufacturers may not be; see bulk shea butter and UK rules.
- Who is named on the label, and is that address in the UK and not a PO box?
- Does a safety report exist for this exact formula?
- Is the product notified before the first sale?
- Are you also handling customs correctly: an EORI number and the right commodity code?
Where Pryme fits
Paying for safety reports and supplier batches is easier when the money side is tidy. A Pryme Business Account holds GBP and NGN, so you can pay a Nigerian producer in naira and keep the invoice and payment together, with a verifiable statement from VerifyDoc.ai receipts if a buyer or assessor asks for proof of purchase. The app shows the rate and the fee before you approve.
Questions people ask
Can a Nigerian company be the UK Responsible Person?
Not from Nigeria. OPSS guidance says the Responsible Person must be established in the UK. A Nigerian brand can appoint a UK-established company in writing to act for it.
Do I need a Responsible Person to sell on Amazon or Etsy UK?
Yes. The requirement applies to any cosmetic made available to consumers in Great Britain, whatever the sales channel.
How long must I keep the Product Information File?
For 10 years after the last batch of the product is placed on the market, according to the OPSS guidance updated 16 October 2026.
Is a safety report from Nigeria enough?
Only if it meets the GB requirements and is written by a qualified assessor with the Part A and Part B content. Many importers commission a fresh report in the UK.
Sources
- GOV.UK (OPSS): Making cosmetic products available to consumers in Great Britain (updated 16 Oct 2026) · accessed Oct 2026
- legislation.gov.uk: Regulation (EC) No 1223/2009 on cosmetic products, Article 2 definitions (GB version) · accessed Oct 2026
- GOV.UK (OPSS): Product safety report, skin lightening lotion containing hydroquinone, 2406-0049c (19 Jun 2024) · accessed Oct 2026
- GOV.UK (OPSS): Submit a cosmetic product notification (last updated 31 Dec 2020) · 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.