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Common Questions

What services do you provide?
We provide GPSR EU Responsible Person services, product documentation and labelling support, Cosmetics Responsible Person and CPNP notification services, and EU Declaration of Conformity drafting support for eligible products.What products do you support?
We support a range of general consumer products, cosmetics, and eligible products subject to CE marking requirements. Acceptance depends on the product type, intended use, applicable EU legislation, risk profile and available compliance documentation.What does your GPSR EU Responsible Person service include?
For accepted products, we act as the EU Responsible Person, maintain the relevant compliance information, support communication with market surveillance authorities, and provide product documentation, labelling and online listing guidance within the agreed service scope.What does the Cosmetics Responsible Person service include?
For eligible cosmetic products with the required safety and product documentation already prepared, we can provide Responsible Person services, review the product information and labelling, and complete the CPNP notification. CPSR preparation, testing and full PIF creation are not included unless separately agreed.What does your EU Declaration of Conformity service include?
We review the product information and available compliance documentation, identify the relevant EU legislation and standards, and prepare or revise the EU Declaration of Conformity where the available evidence is sufficient. Testing, certification and laboratory services are not included.How do I get started?
Select the relevant service and provide the requested product information and documents. The exact process depends on the service. Where a preliminary review is required, such as EU Declaration of Conformity support, we will review the enquiry before confirming the scope and payment. For document requirements and service-specific questions, please see our detailed FAQ.

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FAQ

Why do I need an EU Responsible Person when selling consumer products in the EU?There must be an economic operator based in the EU who can respond to requests for documentation from EU authorities and cooperate with necessary safety measures if a product safety issue arises. For products subject to the GPSR’s Responsible Person requirements, you must appoint an EU Responsible Person if an existing EU manufacturer, importer or other relevant economic operator does not already fulfil this role. Small businesses and handmade sellers are not exempt solely because of their business size.What do I need to prepare to appoint a GPSR EU Responsible Person?Please send the following information so we can review your product’s characteristics and safety information.• Product name, model or SKU, intended use and expected users
• Product and packaging photos, existing labels and instructions for use, and links to sales listings
• Information on materials and key components, and the names, addresses and contact details of the manufacturer and suppliers
• Seller details and the EU countries where you intend to sell
• Risk assessments, technical documentation, and any available test reports and supplier declarationsYou can start by sending the information you currently have. We will guide you on organising the basic product documentation and any additional information or documents needed. The GPSR requires a safety assessment and technical documentation appropriate to the risks associated with the product.Which products require additional supporting documentation?We review additional safety documentation for products that present greater risks due to their users or materials, or that are subject to specific legislation. Common examples include:• Children’s products: Information on the intended age group and choking or strangulation risks associated with small parts, cords and similar features
• Jewellery and metal accessories: Material and plating information, and documentation on nickel release and restricted substances such as lead and cadmium
• Candles and diffusers: Composition information, safety data sheets (SDS), applicable chemical labelling information, and fire safety and safe-use information
• Toys and electrical or electronic products: Test and assessment documentation and technical documentation under the applicable CE marking legislationWe will advise on the documents needed based on each product’s risks and applicable requirements.What documents are required for food contact products such as tableware and cups?To assess the risk of harmful substances migrating into food, we review food contact material (FCM) requirements alongside the GPSR. Please prepare the following:• Information on materials, coatings and glazes that come into contact with food
• Types of food the product will contact, contact temperature and duration, and whether it is intended for repeated use
• A Declaration of Compliance (DoC) for food contact use, where required for the relevant material or country of sale
• Supporting safety documentation, such as migration or leaching test reports reflecting the intended conditions of use
• Manufacturer and supplier details, good manufacturing practice (GMP) documentation, and batch traceability recordsFor example, the substances and test parameters to be assessed differ between plastics and ceramics. It is important that the documentation covers the materials and intended conditions of use of the products you plan to sell.What documents are required to draft or revise an EU Declaration of Conformity (CE DoC)?We need the following documents to check that the declaration accurately reflects the product and its conformity assessment results:• Product name, brand, model list, specifications and product photos
• Manufacturer’s name and address, and the name and position of the person signing the declaration
• Test reports and assessment documentation covering the applicable legislation, such as LVD, EMC, RoHS and relevant Ecodesign requirements
• Technical documentation, including risk assessments, design drawings, circuit diagrams and lists of key components
• Product and packaging labels, instructions for use, and a copy of any existing DoCIf the model names in the test documentation differ from those of the products being sold, we also need an explanation from the manufacturer of how the models are related. We review the supplied documentation and prepare a draft DoC for the manufacturer to review and sign.What kind of PIF is required for the Cosmetics Responsible Person and CPNP services?We proceed with RP appointment and CPNP notification after reviewing the product’s safety and labelling. A complete Product Information File (PIF), including a Cosmetic Product Safety Report (CPSR), is therefore required. Its main contents should include:• Product description and intended use, full ingredient list and formulation percentages, and raw material and fragrance allergen documentation
• CPSR Parts A and B, signed by a qualified safety assessor, together with evidence of the assessor’s qualifications
• Stability, microbiological and packaging safety data, and preservative efficacy test data where necessary
• Manufacturing method and a statement of compliance with good manufacturing practice (GMP)
• Evidence supporting product efficacy and marketing claims
• Information on whether the manufacturer, suppliers or other relevant parties have carried out animal testing, and any related detailsPlease also send the EU label artwork and product and packaging photos for label review and CPNP notification. Preparation of the PIF and CPSR is not included in the service.Do you also provide EPR and PPWR support?No. We can provide briefings and general guidance on the main obligations, application timelines and matters to check in each country of sale concerning packaging EPR and the PPWR. This support is separate from our GPSR EU Responsible Person service, as packaging EPR and PPWR obligations are distinct from the appointment of a Responsible Person under the GPSR. We do not provide national EPR registration, periodic reporting or fee payment services, or act as an authorised representative for packaging EPR.

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Terms and Conditions

Last updated: 8 October 2026These Terms and Conditions apply to the EU Responsible Person & GPSR Compliance Services, EU Cosmetics Responsible Person services, and CE & EU Declaration of Conformity services provided by Optimaalcert OÜ under the Optimalcert brand.Our services are intended for business customers acting for purposes connected with their trade, business, craft or profession. This includes sole traders and individuals purchasing support for commercial activities.You agree to these Terms when, after they have been made available to you, you accept them when placing an order, accept a quotation incorporating them, expressly instruct us to begin paid services subject to them, or sign a Mandate incorporating them. A general enquiry or request for information alone does not create a paid service contract or an EU Responsible Person appointment.1. Definitions“Service Provider”, “we”, “us” and “our” mean Optimaalcert OÜ. “Optimalcert” is the brand under which we provide the services.“Client”, “you” and “your” mean the business customer purchasing or requesting the services. Anyone acting for the Client must have authority to bind that business and provide the relevant product information.“Product” means a product identified in the agreed service scope, including its relevant model, formulation, variants and identifiers. A “Product Type” is a group assessed together for GPSR plan purposes because the products have sufficiently similar intended use, design, materials and safety requirements. Product Types are not necessarily the same as individual SKUs or listings.“Service Order” means the purchased package or accepted quotation, together with the agreed scope, price, service period and any written product acceptance. “Product Schedule” or “Annex” means the record identifying the accepted products, Product Types, models, formulations and included variants.“GPSR” means Regulation (EU) 2023/988 on general product safety. “Cosmetics Regulation” means Regulation (EC) No 1223/2009 on cosmetic products. References to legislation include applicable amendments and replacements, subject to their application dates and transitional provisions.“GPSR Responsible Person” means the EU-based economic operator performing the tasks required by Article 16 of the GPSR and related applicable legislation for products for which we have accepted that role. “Cosmetics Responsible Person” means the EU-established person validly designated under Article 4 of the Cosmetics Regulation. “EU Responsible Person” means the relevant role expressly accepted by us for the product concerned.“Mandate” means the written appointment from the manufacturer, importer or other person legally entitled to make that appointment, together with our written acceptance and the identified product scope. A commercial order or payment receipt does not, by itself, satisfy any statutory requirement for a written appointment.“PIF” means the Product Information File required by Article 11 of the Cosmetics Regulation. “CPSR” means the Cosmetic Product Safety Report required by Article 10 and Annex I. “CPNP” means the Cosmetic Products Notification Portal. “SUE” means a serious undesirable effect as defined in the Cosmetics Regulation.“DoC” means the applicable EU declaration of conformity or, where the relevant legislation uses that term, declaration of compliance. The document and requirements depend on the product and applicable legislation.2. Scope of Services and OrderingEU Responsible Person & GPSR Compliance Services provide GPSR support for eligible consumer products. Depending on the purchased plan, this includes EU Responsible Person appointment, product information and documentation support, risk assessment support, labelling and online listing guidance, and ongoing compliance support. The Starter plan covers up to 2 accepted Product Types. The Standard plan covers up to 5 accepted Product Types.We assess Product Type grouping using the criteria in Section 1 and confirm the accepted scope in writing. Multiple SKUs, sizes or colours may be included within one Product Type where their differences do not require a separate safety assessment. Products with materially different uses, construction, materials or risks may count separately. If the submission exceeds the purchased limit, we will explain the grouping and agree any upgrade or additional work before charging for it.EU Cosmetics Responsible Person services provide support relating to the Cosmetics Regulation for up to 5 accepted cosmetic products. This includes documentation and label review, PIF availability and administration, CPNP notification and relevant updates, Responsible Person appointment, and ongoing regulatory support within the agreed package. Different formulations, fragrances, shades or intended uses may require separate review and may count as separate products unless expressly grouped in the agreed scope.CE & EU Declaration of Conformity services provide document review, identification of relevant legislation and standards, compliance gap review, and drafting or revision support for products being prepared for CE marking or requiring declarations of conformity or compliance for the EU market. The applicable declaration must be supported by appropriate conformity evidence. Preparing a declaration does not itself establish product conformity or replace required assessment or testing. The manufacturer or other legally responsible declarant must approve and sign the final document, or arrange signature by a properly authorised person where the applicable legislation permits this.Eligible GPSR and cosmetics packages offered for direct purchase may be ordered and paid for before the detailed review. CE & EU Declaration of Conformity services always begin with an enquiry and preliminary review of the available product information and supporting documents. We confirm whether we can assist, the proposed scope and the price before requesting payment. Declaration drafting or revision begins after payment and receipt of the documents sufficient for that work. Other services or product categories identified as requiring an enquiry, separate review or custom quotation must also be discussed with us before purchase. If you are unsure which service applies, contact us before ordering.The purchased package, accepted quotation and written scope identify the commercial services included. An order for review or onboarding does not itself constitute acceptance of the product for an EU Responsible Person appointment. Appointment is governed by Sections 6 and 7.Only identified and accepted products and variants are included. Routine production batches that remain consistent with the accepted product and documentation do not require a new order solely because the batch number changes, unless the agreed scope provides otherwise. Material changes remain subject to Section 9.

3. Products Requiring Prior Enquiry and Excluded ServicesOur standard GPSR packages are intended for eligible general consumer products. Cosmetics require the separate cosmetics service. Food, food-contact products, medical devices, personal protective equipment, toys, products intended for children under 14, childcare articles, electrical or electronic products, battery-powered products, chemical mixtures and other products subject to specialist legislation require prior enquiry and separate scope confirmation before any service can be accepted.These are limits of our standard packages. Sector-specific legislation and the GPSR may both apply to a product, depending on the requirements and risks concerned. Acceptance for CE or DoC document support does not automatically include an EU Responsible Person or authorised representative appointment.We may decline products that are outside our capabilities, inadequately documented, unsuitable for the purchased package or associated with risks we cannot responsibly support. If a prepaid order cannot be accepted, Section 15 applies.Unless expressly included in a separate written agreement, our services do not include laboratory testing, product certification, notified body services, performance of a complete CE conformity assessment, preparation of a CPSR or compilation of a complete PIF from missing underlying evidence, independent toxicological or scientific assessment, GMP certification, full REACH or CLP assessment, Safety Data Sheet preparation, clinical testing, medicinal or biocidal product assessment, customs clearance, tax advice, VAT or IOSS registration, legal or court representation, or marketplace account management.Packaging compliance, PPWR advice, packaging or other EPR registration, national producer responsibility organisation registration, EPR reporting and an authorised representative appointment for EPR are separate matters. They are not included merely because we act as EU Responsible Person or provide product DoC support. Any packaging documentation or PPWR guidance we agree to provide must be specifically identified in the scope.4. Client Information and DocumentsYou must provide accurate, complete and current information sufficient for the purchased service, including product identification, intended use and users, manufacturer and supplier details, materials or composition, relevant photographs, packaging, labels, warnings, listing information and available compliance evidence.For cosmetics, this includes the complete qualitative and quantitative formulation, CPSR, PIF and supporting records, supplier and raw-material documentation, relevant test and stability information, GMP evidence, claims support, final artwork, batch identification and relevant safety information. You must give us continuing access to information needed to fulfil our Responsible Person obligations.For CE or other DoC support, this includes the manufacturer or responsible declarant, exact product and model identification, specifications, relevant technical documentation, test reports and other evidence supporting the declaration. Documents must be relevant to the product concerned, and any relationship between factory models, brand models and variants must be demonstrated.We may rely on information and third-party evidence that reasonably appear reliable, while applying the professional care and statutory checks required for our role. You remain responsible for the accuracy and authenticity of your submissions and for obtaining missing evidence from manufacturers, suppliers, laboratories or other third parties.If information is incomplete, inconsistent or insufficient, we may request clarification, pause the affected work or decline the affected product. We will explain material gaps and any proposed change of scope or additional charge. A pause does not create Responsible Person coverage or remove existing statutory obligations.5. No Certification or Guaranteed OutcomeWe will perform the agreed services with reasonable professional care and comply with the statutory duties attached to any role we accept.Our review, documentation, declaration drafting, labelling guidance, CPNP submission or Responsible Person appointment does not constitute product certification, an authority's approval or a guarantee of product safety, effectiveness, regulatory acceptance or marketplace acceptance. CPNP notification is an administrative notification, not a marketing authorisation.We do not guarantee customs release, removal of a regulatory finding, acceptance by a marketplace or any particular decision by an authority or third party. You remain responsible for your own obligations as manufacturer, importer, distributor, seller or brand owner. These statements do not exclude or transfer duties or liability that the law places on us.6. GPSR Responsible Person ServiceA GPSR Responsible Person appointment requires the appropriate written Mandate from the manufacturer, or a person demonstrably acting with the manufacturer's authority, our written acceptance, an identified product scope and a stated effective date. Where other product legislation applies, any additional appointment requirements must also be satisfied.Payment, an automated receipt, submission of documents or preliminary review alone does not activate the appointment. You may use our details for the role only after we have confirmed acceptance and the effective date has been reached.For accepted products, we perform the mandatory tasks applicable to our role under the GPSR and, where relevant, Regulation (EU) 2019/1020. These include the required documentation and labelling checks, making relevant information available to authorities, regulatory communication, reporting where required, and cooperation on measures needed to address non-compliance or safety risks. A plan's commercial support limits do not reduce these statutory duties.The appointment applies to the products and included variants identified in the Mandate and Product Schedule. Other products and material changes require acceptance. Suspension, termination, product transition and continuing statutory obligations are governed by Sections 12, 14 and 16.

7. EU Cosmetics Responsible Person ServiceAppointment requires a legally valid written designation under Article 4 of the Cosmetics Regulation by the manufacturer, importer or other party entitled to make it, our written acceptance, identification of the covered products and a stated effective date. You must demonstrate the necessary authority within the supply chain. We may require signatures or equivalent written evidence sufficient to satisfy the applicable legal requirements; payment alone is not a written mandate.The appointment starts only on the effective date stated in the accepted Mandate, after the required review and acceptance. You must not market the product with our Responsible Person details before that date.Before market placement, an appropriate CPSR prepared and signed by a qualified safety assessor, a complete PIF and the necessary supporting evidence must be available. Required CPNP notifications must be completed, and formulation, manufacture, labelling and claims must meet the applicable requirements. Special requirements, including any applicable nanomaterial notification period, may affect the timetable.For accepted products, we fulfil the Responsible Person duties imposed by the Cosmetics Regulation. This includes ensuring the required compliance arrangements, keeping the PIF readily accessible to the competent authorities, maintaining relevant notifications, responding to safety information and undertaking required reporting, cooperation and corrective action. The statutory duties of the role are not reduced by the package price or a commercial exclusion.We review the CPSR and supporting documentation within our competence and may require clarification or updated assessment. The qualified assessor remains responsible for the safety assessment they sign. Reliance on that assessor does not remove our responsibility to ensure that the assessment and required documentation are available and address identified concerns.CPSR creation, missing testing and complete PIF compilation are not included unless expressly agreed. Any separately arranged laboratory or assessor work is subject to an agreed scope and cost. We do not manufacture the product or certify GMP.The appointment covers the accepted formulations, variants, intended uses, claims, labels and packaging configurations, including unchanged batches within that scope. You must inform us promptly about relevant changes, undesirable effects, SUEs, health complaints, defects, authority communications and new safety information, and cooperate with investigations and corrective measures.PIF records must remain available for the statutory period, including ten years after the last batch was placed on the market. Termination requires a lawful transition and does not erase mandatory recordkeeping, safety reporting or other obligations concerning products already placed on the market.8. Client's Product ResponsibilitiesYou remain responsible for your own obligations concerning product design, formulation, manufacture, sourcing, import, sale, distribution, storage, marketing, claims, packaging, labelling and batch conformity. Products actually supplied must correspond to the documentation and scope reviewed.You must ensure that products are safe under normal or reasonably foreseeable use, maintain the required manufacturing, supplier, technical and traceability records, and provide information needed to keep compliance documentation current.You must not place or continue making available products you know, or have reason to believe, are unsafe or non-compliant. You must promptly inform us of relevant concerns affecting accepted products. Your obligations do not replace any statutory obligations attached to our appointment.9. Product ChangesInform us before implementing a material change affecting an accepted product's identity, safety, conformity or review basis. This includes relevant changes to design, formulation, ingredients, concentration, materials, components, suppliers, manufacturing, intended use, target users, packaging, warnings, claims, labelling or models.We will assess whether the change can remain within the accepted scope or requires updated documentation, a revised safety assessment, notification, declaration, label, Mandate or separate product review. Additional fees require prior agreement.Do not assume that an accepted appointment or declaration covers a materially changed product. Where the change affects compliance or appointment scope, obtain our written confirmation before placing the changed product on the market using our details or documents.10. Labels, Warnings and Online ListingsWe may review or suggest product identification, manufacturer and Responsible Person information, warnings, instructions, ingredient lists, claims and listing content within the agreed service.You must correctly implement the final information on the product, container, packaging, accompanying documents and online offer as required by the legislation concerned. Mandatory information must be accurate, legible, sufficiently durable where required, current and provided in the languages required by each country of sale.For distance sales, ensure the offer contains the manufacturer, EU Responsible Person, product identification, image, warning and safety information required for that product. Local translations, packaging changes and listing changes must not alter the meaning or omit required information.We are not responsible for implementation or translation errors made independently of our instructions, except to the extent that our own breach or failure to exercise required care contributed to the error. Relevant changes must be notified under Section 9.11. Authority, Platform and Consumer CommunicationsWhere appointed, we handle regulatory and product safety communications required for the accepted products. You must provide timely access to documents, sales and distribution records, complaints, photographs, batch information and corrective action details needed to respond.Ordinary customer service, delivery disputes, exchanges, commercial warranties and change-of-mind returns are not included unless separately agreed. A communication involving a possible safety issue, accident, injury, undesirable effect, SUE or product defect must be treated as a safety matter even if it also involves a customer service request.We may contact competent authorities and other relevant parties where necessary to fulfil our legal duties or protect product safety. Additional commercial representation or extensive response drafting outside the purchased package may be separately scoped, without restricting mandatory regulatory action.12. Recalls, Withdrawals and Corrective ActionsWe will perform the reporting, cooperation, assessment and corrective-action duties that applicable law places on us as Responsible Person. Mandatory action will not be withheld solely because additional commercial fees have not been agreed or paid.You must cooperate promptly and fund and carry out the corrective measures for which you are responsible, including suspension of sales, withdrawal, recall, consumer notices, refunds, repair, replacement, disposal, reformulation, testing and document or label updates.Operational campaigns, logistics, additional investigations and crisis management beyond the package's ordinary support may require separate arrangements and charges. This does not limit statutory duties or excuse any party from taking necessary action.Where justified, we may require sales to stop, request further evidence or contact authorities and relevant platforms. Failure to cooperate may result in suspension or termination under Section 16.

13. Fees, Advance Payment and CommencementFees are payable in advance unless expressly agreed otherwise in writing. The price, any setup fee, product limit, billing interval, service period, taxes and included work are those disclosed for the selected package or accepted quotation before purchase.For eligible direct-purchase GPSR and cosmetics packages, payment authorises us to proceed with the agreed review and onboarding once the required intake information and documents have been received.For CE & EU Declaration of Conformity services, you must first enquire and provide the available product information and documents for a preliminary review. We then confirm the proposed scope and price. Payment is requested after that review and confirmation, and is due before declaration drafting or revision begins. The preliminary review does not itself include delivery of a final declaration. Any separately chargeable assessment must be identified and agreed before that assessment is undertaken.For other enquiry-based or custom services, scope and price must first be confirmed, followed by payment before the agreed paid work begins unless otherwise agreed.Commercial review and setup work can begin before a product is accepted for appointment. EU Responsible Person status starts separately, under Sections 6 and 7, on the confirmed effective date. Payment does not approve a product or create retrospective coverage.Subscription billing follows the arrangements disclosed before purchase and confirmed in the Service Order. The appointment start date and purchased service period must be identified in writing; a payment receipt must not be treated as confirmation of active representation. If we cannot accept the product, future subscription charges for that rejected appointment will be stopped and the payment will be settled under Section 15.Any completion estimate runs from receipt of payment and the information sufficient for the relevant stage. Missing documents, product changes, assessor or laboratory work and third-party delays may affect the estimate. We will communicate material delays or additional requirements.Work outside the agreed scope requires agreement on the additional scope and price before it is charged. This does not prevent mandatory safety or regulatory action under Section 12.14. Renewal and Service PeriodThe Service Order and Mandate identify the service period and appointment dates. A service renews automatically only where recurring renewal and billing have been disclosed and accepted before purchase. Otherwise, renewal requires a further agreement and payment.You may stop future renewals through the available subscription mechanism or by emailing us before the next renewal is processed. Stopping renewal normally leaves the current paid service period in place. Earlier cancellation and refund rights are addressed in Section 15.We will give reasonable advance notice of proposed price or scope changes for a future renewal. A renewal payment does not add unaccepted products or variants to the appointment.Before expiry or termination, you must arrange any legally necessary replacement Responsible Person and related changes to labels, listings, notifications and documentation. Section 16 governs transition and obligations concerning existing products.15. Cancellation, Refusal and RefundsThese are business services. A statutory consumer cooling-off right does not arise merely because a business customer orders online. Nothing in these Terms removes any withdrawal, cancellation, refund or other remedy that applies under mandatory law.If you cancel before any agreed review, onboarding or other work has started, and before any appointment period has begun, we will refund the advance payment.If cancellation takes effect after work has begun, the amount due is assessed by reference to the agreed price, work properly performed, the service period provided, approved expenses and any further remuneration recoverable under applicable law. Required deductions for saved costs and other relevant adjustments will be taken into account. Beginning a review does not automatically make the entire prepaid package non-refundable.Review or setup work included within a package may be taken into account at a reasonable value within the agreed price. We will not introduce an undisclosed fixed setup charge after cancellation. We will explain any amount retained and refund the balance due.Stopping future renewals does not automatically cancel a service period already in progress or create a pro-rata refund for that period. Any right to earlier cancellation and the resulting financial settlement remain subject to applicable law and this Section.If we decline the product or cancel because the purchased service cannot responsibly be provided, we will stop future billing for that service and refund the portion attributable to services or appointment periods not provided. We may retain a reasonable amount for separately identifiable review or setup work properly performed within the agreed scope, but not amounts that must be returned because of our own breach.If documents are missing, we may pause the work, request them and give a reasonable opportunity to respond. Continued failure to provide essential information may lead to cancellation, with a settlement under this Section. Payment does not create coverage during the pause.Refunds due will be processed without undue delay, normally using the original payment method unless another method is agreed. This Section does not restrict remedies for defective services or our breach of contract.16. Suspension, Termination and TransitionEither party may terminate in accordance with the Service Order and applicable law. We may suspend affected commercial work or terminate an appointment for material non-payment, false or misleading information, unapproved material changes, misuse of our details, failure to cooperate or serious safety or compliance concerns.Where the issue can reasonably be remedied, we will normally give notice and an opportunity to remedy it. Immediate measures may be necessary where required by law, where there is an urgent safety risk or where continued appointment cannot lawfully or reasonably be maintained. Where the GPSR requires termination of a manufacturer's mandate and notification to authorities, we will comply.Termination for other reasons requires reasonable notice taking account of the service and the opportunity to arrange a lawful replacement. Suspension of commercial work does not itself switch off statutory Responsible Person duties.Once an appointment ends, you must not use our details to place further products on the market or present us as the current Responsible Person without a continuing valid appointment. We will identify the effective date and cooperate with necessary transfer of records and notifications to an appropriately appointed successor.Products already placed on the market, existing stock and historical records must be handled through a lawful transition rather than by simply deleting our details or regulatory records. Statutory recordkeeping, reporting and other duties that survive termination remain unaffected. Any financial settlement arising from termination is governed by Section 15.

17. Use of Our Name, Details and DocumentsUse our name, address and contact details only for accepted products, the agreed role and the period of a valid appointment. Do not use them for other products, materially changed products or a different regulatory role without written acceptance.Do not describe our involvement as certification, official approval, product endorsement, insurance or a guarantee of safety or full compliance. A Mandate confirms the appointment and scope; it is not a product certificate.Subject to payment and any agreed licence conditions, you may continue to use final documents we prepared for their agreed purpose while they remain accurate and applicable. Their continued use does not imply an ongoing Responsible Person appointment. Historical records may be retained as required by law, but must not be used to misrepresent current appointment status.18. Limitation of LiabilityWe are responsible for performing our agreed services with the care required by the contract and applicable law. We are not responsible for product defects, manufacturing or supplier failures, inaccurate Client information or independent implementation errors except to the extent our own breach contributed to the loss.To the extent permitted by law and reasonable in the circumstances, we exclude liability for indirect or consequential loss, including lost profits and lost business opportunities. Third-party or authority outcomes are not guaranteed as explained in Section 5.Subject to the exceptions below, our aggregate contractual liability for a one-off Service Order is limited to the fee paid or payable for that order. For an ongoing service, it is limited to the fees paid or payable for that service during the twelve months preceding the event giving rise to the claim, or during its shorter period of operation.These limits do not apply to fraud, intentional misconduct, gross negligence, death or personal injury caused by our negligence, or any liability that cannot lawfully or reasonably be excluded or limited. They do not limit authorities' powers, third parties' statutory rights, our mandatory regulatory duties or amounts that must be refunded under Section 15.19. Client IndemnityTo the extent permitted by law, you must reimburse reasonable, substantiated losses and expenses we incur from third-party claims caused by your breach, materially false or incomplete information, unlawful use of our details, unsafe or non-compliant products, or failure to implement necessary corrective measures.This obligation applies only to the extent the loss is attributable to those matters. It does not cover our own breach, negligence or misconduct, or transfer a statutory liability, fine or sanction that cannot lawfully be transferred. We will notify you of relevant claims and reasonably cooperate to limit the loss.20. Nature of Compliance SupportWe provide practical product compliance and documentation support within the agreed scope. Unless expressly agreed with an appropriately qualified professional, this does not establish a lawyer-client relationship or include legal or court representation.Specialist legal, scientific, laboratory or notified body advice may be needed for matters beyond our competence, including disputed enforcement proceedings or requirements outside the agreed service. We will identify material issues requiring separate expertise when they become apparent during our work.21. ConfidentialityEach party must protect the other's non-public business, technical, product, supplier and commercial information and use it only for the agreed services, lawful regulatory purposes or enforcement of legitimate contractual rights.Information may be disclosed to personnel and professional service providers who need it and are subject to appropriate confidentiality obligations, or where required by law, authorities or necessary product safety action. Disclosures must be limited to what is reasonably necessary. Information already lawfully public or independently obtained without confidentiality restrictions is not covered by this obligation.22. Data ProtectionPersonal data will be processed in accordance with Regulation (EU) 2016/679 and applicable data protection law. We use necessary contact, business, order and communication information to provide services, manage the contractual relationship, maintain required records and meet legal obligations.You must provide personal data lawfully and limit submissions to information relevant to the service. Safety and complaint information, including any health information, must be handled using an appropriate legal basis and safeguards. We will retain data only for legitimate service needs and applicable legal retention periods.We will provide the privacy information required by law and enter into any separate data processing arrangements required for the parties' actual roles. This clause does not replace those disclosures or arrangements. Data protection enquiries may be sent to the contact address in Section 26.23. Force MajeureA party is excused from affected performance only to the extent that an event outside its reasonable control, which could not reasonably have been anticipated, avoided or overcome, prevents performance under applicable law. Such events may include serious infrastructure disruption, natural disasters, war or binding government measures.The affected party must promptly inform the other, take reasonable steps to reduce the effects and resume performance when possible. An authority delay, supplier failure, platform action or change in law is not automatically force majeure merely because it occurs.Existing payment and refund rights and mandatory product safety duties remain subject to applicable law. If the disruption continues, either party may exercise any applicable right to terminate, with settlement under Section 15.24. Changes to These TermsThe version made available and accepted when the Service Order is entered into applies to that order. Later website updates do not automatically rewrite an existing contract or remove accrued rights.Material changes to ongoing services will be notified in advance and take effect by agreement or for a future renewal following reasonable notice. We will identify any related change to price or scope before it applies. If you do not wish to renew on the revised terms, you may stop renewal under Section 14.Changes required by applicable law will be implemented when legally necessary. They do not remove accrued claims or mandatory cancellation, refund or other rights. If an ongoing service can no longer lawfully be provided, Sections 15 and 16 apply.25. Governing Law and JurisdictionThese Terms and the Service Order are governed by Estonian law. The competent courts of Estonia have jurisdiction over disputes, except where mandatory rules require otherwise.The parties should first attempt to resolve a dispute through direct communication, without preventing either party from seeking urgent relief or exercising legal rights. If a provision is invalid, the remaining provisions continue to apply to the extent permitted by law.26. ContactSite operator and contracting entity: Optimaalcert OÜ
Brand: Optimalcert
Business registration number: 17497648
Business address: Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551, Estonia
Email: [email protected]

Refund and Cancellation Policy

Last updated: 8 October 20261. ScopeThis policy explains cancellations, refunds and subscription changes for services provided by Optimaalcert OÜ under the Optimalcert brand. It covers EU Responsible Person & GPSR Compliance Services, including practical GPSR documentation, labelling and product safety support for eligible consumer products; EU Cosmetics Responsible Person services, including documentation and label review and CPNP notification support; and CE & EU Declaration of Conformity services, including documentation review and Declaration of Conformity drafting support for eligible products subject to CE marking requirements.
Your purchased plan, service offer or written agreement defines the products covered, included services, fees and prerequisites. This policy does not restrict rights that cannot lawfully be excluded.2. Payment and product eligibility
Payment is collected in advance unless the relevant service offer states otherwise. Payment alone does not confirm final product eligibility, acceptance for Responsible Person services, readiness for CPNP notification or readiness for an EU Declaration of Conformity.
Initial enquiries are free and do not create a paid service obligation or guarantee acceptance. Any general indication provided before purchase is based only on the information available at that stage and does not constitute a detailed compliance or documentation review.
After payment, we review the submitted product information and documentation as part of the purchased service in order to confirm the applicable requirements, product eligibility and service scope. Additional paid work or changes to the purchased scope require your agreement before we proceed.
If we determine that we cannot provide the purchased service before paid work has begun, we will refund the payment for that service. Where a separately priced documentation review was expressly agreed in advance and has been performed, its fee remains subject to the completed-work provisions below, even if the review identifies issues preventing further services.3. When paid work beginsPaid work begins when we start activities within the purchased or expressly agreed scope. These may include reviewing product information, technical documentation, CPSRs or PIFs; checking labels or listings; preparing product safety documentation; drafting or revising an EU Declaration of Conformity; preparing or submitting a CPNP notification; or setting up Responsible Person support. Responding to an initial enquiry before purchase does not count as paid work.
Responsible Person coverage begins on the date confirmed in writing, subject to the applicable mandate and acceptance requirements. Payment alone does not authorise you to use our Responsible Person details.4. Business customers and cancellationYou are a business customer when you purchase our services for your business or professional activities, including as a sole trader or individual shop owner. The statutory 14-day consumer withdrawal right does not apply to such purchases.
Before paid work begins, a change-of-mind refund is discretionary unless a refund is required by the agreed terms or applicable law. This does not affect our commitment to refund a purchased service that we cannot provide under the eligibility provisions above.
Once paid work has begun, changing your mind does not automatically entitle you to a full refund. Fees attributable to work performed and reasonable, agreed costs already incurred are generally non-refundable.
For partially performed services, we assess the amount payable and any refund under the agreement and applicable law, taking account of the work performed and any required adjustments for costs saved or alternative earnings. We will explain any deductions and refund the remaining balance where due. Starting work does not, by itself, make the entire payment non-refundable.5. Completed work and service issuesFees for completed reviews, prepared documents, label or listing support, CPNP notification work and Responsible Person setup are generally non-refundable for a change of mind.
An agreed review may identify missing evidence, necessary corrections or product ineligibility. Such findings do not, by themselves, mean that the review service has not been provided.
If our work contains an error caused by us, please contact us. We will seek to correct it within a reasonable time without an additional fee. This does not restrict your rights to cancellation, a refund or other remedies where we fail to provide the agreed service, breach the contract or applicable law requires a remedy.6. Responsible Person services and CPNP notificationsCancellation of GPSR or cosmetics Responsible Person services takes effect on the date confirmed under the agreement or applicable law. It does not retrospectively cancel the period during which we acted as Responsible Person or erase service records.
From the effective termination date, you must stop using our details for new product labels, packaging, listings or further placement of products on the market, unless we agree otherwise in writing and the arrangement is lawful. Products already placed on the market, outstanding regulatory matters and any handover to a replacement Responsible Person must be addressed under the mandate and applicable requirements.Cancelling cosmetics Responsible Person services does not automatically delete or transfer an existing CPNP notification. Any necessary notification updates or transfer arrangements must be addressed as part of the transition. We retain records and fulfil any continuing duties required by law.7. Subscriptions and renewalsYou may stop future renewals of a monthly or annually renewing subscription by contacting us before the next billing date. Cancellation of renewal does not normally create a refund for the current paid period where the agreed ongoing service remains available.
Unless termination takes effect earlier under the agreement or applicable law, ongoing support continues until the end of the paid period. Any separately charged setup, review or document preparation fees are assessed under the cancellation and completed-work provisions above. Statutory withdrawal rights and rights arising from a breach of contract remain unaffected.8. Third-party decisionsWe do not guarantee approval, listing reinstatement, customs clearance or acceptance by a marketplace, authority or other third party. An unfavourable third-party decision does not, by itself, entitle you to a refund where we have properly provided the agreed service. This does not exclude responsibility for our own contractual obligations or errors.9. Cancellation requests and refundsTo request cancellation or a refund, email [email protected]. Please provide your name, business or shop name where applicable, the service and product concerned, and your invoice or order reference if available. For business refund requests, please explain the reason so that we can assess the request. A reason is not required when exercising a statutory consumer withdrawal right.
Refunds are normally issued using the original payment method unless another method is agreed. We issue approved refunds without undue delay and within any applicable legal deadline. The time taken for the funds to appear in your account may depend on the payment provider.10. ContactSite operator and contracting entity: Optimaalcert OÜ
Business registration number: 17497648
Business address: Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551, Estonia
Email: [email protected]

Privacy Policy

Last updated: 8 October 2026This Privacy Policy explains how Optimaalcert OÜ, trading as Optimalcert, collects and uses personal data when you visit our website, contact us, submit product information or documents, purchase our services, or communicate with us about product compliance or safety.It covers our GPSR EU Responsible Person services, Cosmetics Responsible Person and CPNP notification services, product documentation and labelling support, and EU Declaration of Conformity drafting and revision support. We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or GDPR), the Estonian Personal Data Protection Act, and other applicable legislation.1. Who is responsible for your personal dataThe controller is Optimaalcert OÜ, an Estonian company with registry code 17497648, operating under the name Optimalcert. Our registered address is Ahtri tn 12, Kesklinna linnaosa, 15551 Tallinn, Estonia.You can contact us about this policy, our use of personal data, or your data protection rights at [email protected] or by writing to our registered address. Our website is https://optimalcert.com.We act as a controller when we determine how personal data is used to operate our business, manage client relationships, and fulfil our own Responsible Person or other legal obligations. If a particular service involves processing personal data solely on a client's documented instructions, that processing is governed by an appropriate data processing agreement where required.2. Personal data we collect and its sourcesDepending on your interaction with us, we collect names, business roles, email addresses, telephone numbers, business or correspondence addresses, business registration and tax details, and website or online shop addresses. Information relating only to a legal entity is not itself personal data, but details identifying sole traders, employees, directors, or other individuals are covered by this policy.We also process enquiry and correspondence records, submitted forms and attachments, order and subscription information, invoices, payment confirmations, transaction references, cancellation and refund requests, mandates, signatures, and records of service delivery. Information contained in product documentation may identify manufacturers, suppliers, signatories, safety assessors, testing professionals, or other business contacts. This may include names, professional qualifications, contact details, and signatures in technical files, declarations, PIFs, CPSRs, labels, and supporting documents.Our website and the providers supporting it may process technical information such as IP addresses, browser and device details, pages requested, access times, referring pages, error or security records, and cookie preferences. Where optional measurement tools are enabled with the required consent, they may also process advertising identifiers and information about visits, enquiries, or completed purchases.We obtain data directly from you, from your organisation or its authorised representatives, and from the documents and links submitted for review. Where relevant to a service or product-safety matter, we may also obtain information from manufacturers, suppliers, safety assessors, laboratories, customers reporting an issue, online marketplaces, public business registers, publicly accessible business websites or listings, and competent authorities. When we obtain personal data indirectly, we provide the information required by Article 14 GDPR within the applicable time limits unless a lawful exception applies.Please provide only personal data relevant to your request. Remove unnecessary customer information and other unrelated identifiers from submitted documents. If identifiable health information is needed for a product-safety investigation, we provide additional information about its use, recipients, retention, and the applicable Article 6 legal basis and Article 9 condition before requesting it. We obtain explicit consent where that is the appropriate condition; processing necessary for legal claims or statutory public-health duties must satisfy the relevant legal conditions and safeguards.3. Why we use personal data and our legal basesWe use personal data to respond to enquiries, review service eligibility, assess submitted information, prepare quotations, and take requested steps before entering into a contract. When you are personally the prospective contracting party, including as a sole trader, the legal basis is Article 6(1)(b) GDPR. When you act for a company or another organisation, the legal basis is Article 6(1)(f): our legitimate interest in communicating with business representatives and assessing prospective business relationships.We use personal data to administer orders, payments, subscriptions, renewals, mandates, refunds, and cancellations; review documents and labels; prepare agreed documentation; and provide ongoing support. We rely on Article 6(1)(b) where this is necessary for a contract with you personally, and Article 6(1)(f) where we administer a contract with the organisation you represent. Our legitimate interest is to deliver and document the agreed service and maintain the business relationship.We use necessary personal data to comply with accounting and tax requirements, maintain legally required product-compliance information, make required notifications, respond to lawful authority requests, and fulfil applicable Responsible Person and product-safety obligations. The legal basis is Article 6(1)(c) GDPR. Depending on our appointment and the product concerned, these obligations may arise under Estonian accounting and tax legislation, Regulation (EU) 2023/988, Regulation (EC) No 1223/2009, Regulation (EU) 2019/1020, or other applicable product legislation.We use relevant information to investigate complaints and suspected misuse of our Responsible Person details, maintain website and information security, prevent fraud, and establish, exercise, or defend legal claims. Where this processing is not required by law, we rely on Article 6(1)(f). Our legitimate interests are protecting our systems, clients, services, and legal rights and supporting appropriate product-safety investigations.Where we rely on legitimate interests, we assess whether the processing is necessary and proportionate and consider the effects on the individuals concerned. We do not rely on this basis where their interests or fundamental rights override our legitimate interests.We rely on Article 6(1)(a) GDPR for processing that requires your consent, including optional analytics or advertising tracking where applicable. Promotional communications are handled as explained in Section 8. You can withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.4. Information needed to provide services and process paymentsProviding some information is necessary to assess a request, enter into or perform a service contract, or comply with legal obligations. We identify required fields in our forms or explain the requirements when requesting documents. If necessary information is missing, we may be unable to review your product, confirm eligibility, process your order, complete a notification, or provide or continue the relevant service. Optional information is voluntary.Payment providers and banks process the information needed to complete a payment. We receive the billing information, payment status, transaction references, and any limited payment-method information they make available to us for administering the order. Please do not send complete payment-card details through our general contact forms or by email. A payment provider may also process information as an independent controller for its own fraud-prevention, regulatory, and payment-processing purposes, as explained in its privacy notice.5. Who may receive personal dataWe disclose personal data only where needed for the purposes described in this policy and where there is an appropriate legal basis. Recipients may include providers of website hosting and forms, email and communications, cloud storage, document management and review, electronic signatures, payment processing, banking, accounting, and IT or security support. Where a provider processes personal data on our behalf, we use the contractual arrangements required by Article 28 GDPR.Where necessary for the agreed service, we may share relevant information with selected regulatory or technical professionals, safety assessors, laboratories, manufacturers, or suppliers. We may also disclose information to market surveillance authorities, customs authorities, the European Commission and relevant notification systems, or other competent bodies when required by law or necessary to fulfil our regulatory role. Information submitted through CPNP is accessible to the recipients authorised under the applicable cosmetics rules.Relevant information may be shared with online marketplaces or other platforms when needed to verify an RP appointment, address a compliance issue, or investigate misuse of our details. We may disclose information to legal advisers, insurers, courts, or public authorities where necessary for legal advice, insurance matters, legal claims, or a lawful disclosure obligation. Some recipients act as independent controllers and are responsible for their own processing.We limit disclosures to information relevant to the recipient's role. We do not sell or rent personal data.6. Access and transfers outside the EEAOur company is established in Estonia. Our authorised personnel may carry out work from South Korea, which can involve access to personal data from outside the European Economic Area (EEA). Some providers supporting our services may also process data, or use subprocessors, outside the EEA.We apply appropriate safeguards to overseas access and processing. Where an arrangement constitutes a transfer to a separate recipient outside the EEA under Chapter V GDPR, we use an applicable European Commission adequacy decision or appropriate safeguards, such as the Commission's Standard Contractual Clauses. Where necessary, we assess the destination country's rules and apply supplementary measures. An adequacy decision is relied on only where the relevant recipient and processing fall within its scope.You can contact us for information about the destinations and transfer safeguards applicable to your data and to request a copy of relevant safeguards, subject to necessary redactions protecting confidential information and the rights of others.7. How long we keep personal dataWe keep personal data for the period needed for its specific purpose, taking account of the service provided, legal retention requirements, and relevant limitation periods. Ending a service or withdrawing consent does not remove an independent obligation to retain particular records.Enquiries that do not result in an order are normally retained for up to 12 months after the last substantive contact, unless the enquiry remains active or relevant information is needed for a complaint or legal claim. Routine client relationship and service-administration records are normally retained during the service and for up to three years after it ends, subject to the accounting, regulatory, and claims-related requirements below.Invoices, payment records, and other accounting source documents are retained for seven years from the end of the financial year in which the relevant transaction was recorded, as required by Estonian accounting legislation. Supporting business records are retained for the applicable statutory period.Product-compliance documentation is retained or kept available for the period required by the legislation applicable to the product and our role. For cosmetics, Article 11 of Regulation (EC) No 1223/2009 requires the PIF to be kept for ten years after the last batch of the cosmetic product was placed on the market. Necessary personal data forming part of that file may therefore remain in it for that period. Other product files, mandates, and authority correspondence may also need to remain available after a service ends. These requirements do not justify retaining unrelated personal data.For website and security records, retention is determined by the technical record concerned, the period needed to detect or investigate an incident, and the relevant provider's deletion cycles. Cookie and similar identifier lifetimes are disclosed in the relevant cookie information when those technologies are enabled. Marketing contact details are kept until consent is withdrawn or an objection is received, or until they are no longer needed for permitted communications. We may retain a minimal suppression record to respect an opt-out.Records needed for an actual or reasonably anticipated dispute, investigation, or legal claim are retained until the matter is resolved and the relevant legal retention or limitation period has expired. We then delete or anonymise the information. Residual backup copies are removed through the applicable backup cycle and are not used for ordinary business purposes in the meantime.8. Cookies, advertising measurement, and marketingOur website and external service interfaces may use cookies or similar technologies. Strictly necessary technologies support functions such as secure operation, form submission, payment processing, and recording privacy choices. Technologies falling within a lawful necessity exception do not require cookie consent.If optional analytics or advertising technologies, including Google Ads conversion tracking, are enabled on our website, we obtain consent before using them where required by applicable law. Before activation, the relevant cookie notice or consent interface identifies their purposes, providers, lifetimes, and any third-party access. You can refuse optional technologies and withdraw consent through the available privacy controls as easily as you gave it. Browser settings can also control cookies, although blocking necessary cookies may affect requested functions.We send promotional emails only where permitted by applicable electronic-marketing rules. We rely on consent where required and on legitimate interests for communications covered by a lawful existing-customer or business-contact exception. Public availability of an individual's email address does not itself establish consent. Each promotional message provides a simple way to opt out; you can also contact us at [email protected]. Service messages about your enquiry, order, documents, payments, or product safety are sent on the relevant contractual, legal-obligation, or legitimate-interest basis.9. SecurityWe apply technical and organisational measures appropriate to the nature of the information and the risks of processing. Access is limited to authorised persons and providers who need the information for their work, and personal data is handled under appropriate confidentiality and security arrangements.No system can guarantee absolute security. Where a personal data breach occurs, we assess it and notify the competent supervisory authority and affected individuals when required by GDPR.

10. Your data protection rightsSubject to the conditions in GDPR, you may request access to your personal data and a copy of it, correction of inaccurate or incomplete information, erasure, or restriction of processing. Where processing is based on consent or a contract and carried out by automated means, you may request portability of the personal data you provided in a structured, commonly used, machine-readable format.You may object, on grounds relating to your particular situation, to processing based on legitimate interests. We will stop that processing unless we demonstrate compelling legitimate grounds overriding your interests, rights, and freedoms, or the processing is needed for legal claims. You may object to processing for direct marketing at any time, including any related profiling, and we will stop processing for that purpose.You may withdraw consent at any time where consent is the legal basis. Some rights are subject to exceptions; for example, erasure may not be available for information we must retain to comply with law or for legal claims.To exercise a right, email [email protected]. We may request proportionate information to verify your identity where we have reasonable doubts. We respond without undue delay and normally within one month of receiving a request. Where GDPR permits an extension because of the complexity or number of requests, we may extend the period by up to two further months and explain the reason within the first month. Requests are normally free of charge. We may charge a reasonable fee or refuse a request only where the conditions in GDPR are met, including where a request is manifestly unfounded or excessive.11. Automated decisions and childrenWe do not make decisions about individuals based solely on automated processing that produce legal effects or similarly significantly affect them within the meaning of Article 22 GDPR. Our product and service eligibility decisions involve human review.Our website and services are directed at businesses and are not intended for children. If you believe a child has provided unnecessary personal data to us, please contact us so we can assess the situation and take appropriate action.12. Complaints and changes to this policyYou have the right to lodge a complaint with a competent data protection supervisory authority, including the authority in the EEA country where you habitually reside or work, or where an alleged infringement occurred. In Estonia, the authority is Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate), Tatari 39, 10134 Tallinn, Estonia; email: [email protected]; website: https://www.aki.ee/en. You may contact us about a concern, but doing so does not restrict your right to complain.We may update this policy to reflect changes in our services, processing practices, or legal requirements. The current version is published on our website with its update date. Where a change requires additional information or fresh consent, we provide that information or request consent as required before applying the relevant change.