Who submits the CPNP notification
Notification is the job of the Responsible Person, the role defined in Article 4 of the Regulation: the natural or legal person, established in the EU, who ensures the product complies with the law. Their name and address appear on the label.
- Products manufactured in the EU: the Responsible Person is the manufacturer, unless it designates in writing (by mandate) another person established in the EU, who accepts.
- Imported products: the Responsible Person is the importer, who can in turn designate another person by written mandate.
- Distributors: have a limited notification duty when, on their own initiative, they translate part of the labelling to sell the product in another Member State (Article 13(3)).
In private label, the Responsible Person is usually the brand owner or the manufacturer, as agreed between the parties. For brands based outside the EU, an EU Responsible Person is required: we can provide one through our partners. Access to the portal uses personal credentials, and the Responsible Person can delegate data entry to someone else, such as the manufacturer or a consultant.