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CPNP notification

CPNP notification for cosmetics: what it is and how it works

Every cosmetic product sold in the European Union must be notified on the CPNP before it reaches the market. CPNP notification is free and done once for all Member States, but it follows precise rules. This guide explains who submits it, when, with which data, the most common mistakes, and how the separate UK notification works.

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What the CPNP is

CPNP stands for Cosmetic Products Notification Portal, the EU portal for notifying cosmetic products. It is run by the European Commission and required by Article 13 of Regulation (EC) No 1223/2009, the law that governs cosmetics across the Union.

The information you enter is used by two groups:

  • Competent authorities of the Member States, which use it for market surveillance.
  • Poison centres, which receive composition data so they can act quickly in case of accidental ingestion or exposure.

One notification covers the whole EU market: you do not repeat it country by country, and there is no registration fee. The United Kingdom has had its own, separate notification system since Brexit (see the UK section below).

A notification is not an authorisation

This is the most common misunderstanding. With a CPNP notification you are not asking for permission, and nobody “approves” your product before it goes on sale. You declare that the product exists, who is responsible for it and what it contains. The safety of the product remains the responsibility of whoever places it on the market, and it is demonstrated by the Product Information File (PIF), which authorities can ask to see at any time.

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.

When to notify

Before the product is placed on the market, that is, before it is made available for sale for the first time in the EU. Notifying “around” the launch is not enough: without a notification the product cannot be sold.

Products containing nanomaterials have an extra step. If the nanomaterial is not already regulated in the Annexes of the Regulation (as some colourants, preservatives and UV filters are), Article 16 requires a specific notification six months before the product is placed on the market.

What data you need

Article 13 lists the information to submit:

  1. The category of the product and its name or names, so it can be identified precisely.
  2. The name and address of the Responsible Person, where the PIF is made available.
  3. The country of origin, for imported products.
  4. The Member State in which the product is placed on the market.
  5. Contact details of a physical person to contact if necessary.
  6. The presence of substances in the form of nanomaterials, with their identification and reasonably foreseeable exposure conditions.
  7. The name and identification number of any substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR), category 1A or 1B.
  8. The frame formulation, which allows prompt medical treatment if something goes wrong.

When the product is placed on the market, the original label and, where reasonably legible, a photograph of the packaging are added.

Frame formulation or exact formula

A frame formulation is a standard template, defined by the Commission for each product type, showing ingredient categories and their maximum ranges. If the product fits a template you can use it; otherwise, or by choice, you enter the exact composition or concentration ranges. A frame formulation protects confidentiality better; the exact formula gives poison centres more precise information.

Nanomaterials and CMR substances

These are special cases. CMR substances are in principle banned in cosmetics, except for derogations set out in the Regulation, and must be declared. Nanomaterials, besides the notification, must be followed by the word “nano” in brackets after the ingredient name on the label.

How notification, PIF and label fit together

The notification and the PIF are two different documents that refer to each other:

DocumentWhat it is for
CPNP notificationTells authorities and poison centres that the product exists and what it contains
PIFProves the product is safe and compliant; kept by the Responsible Person
LabelInforms the consumer; also uploaded to the notification

The Responsible Person’s address in the notification and on the label is where authorities can consult the PIF. If one changes, the others must change too. Everything about the label is in our guide to EU cosmetic labelling.

Selling in the UK: SCPN notification

Since Brexit, Great Britain has its own rules: the UK Cosmetics Regulation, the British version of Regulation 1223/2009. The logic is the same as in the EU, but the system is separate, so a CPNP notification does not cover the UK.

  • SCPN (Submit Cosmetic Product Notification): the UK notification service. A cosmetic product must be notified there before it is placed on the market in Great Britain.
  • UK Responsible Person: a person established in the UK who takes on the role the EU Responsible Person has in the Union. Their name and address go on the label for the UK market, and they keep the product information file.
  • Northern Ireland: special rules apply. Check them for your specific case before you plan sales there.

We do not submit UK notifications ourselves: SCPN notification and the UK Responsible Person are available through our partners, coordinated by the same project manager who follows your EU documents. Official guidance is published on gov.uk.

Common mistakes

  • Notifying after launch: the product must be notified before it goes on sale. Each Member State sets its own penalties for missing notifications.
  • Treating it as an approval: a notification does not certify safety; you still need a complete PIF.
  • Not updating it: if the formula, label, Responsible Person or address changes, the data in the portal must be updated (Article 13(7)).
  • Forgetting the label: the original label and a photo of the packaging must be uploaded when the product reaches the market.
  • Wrong category: a poorly chosen category leads to the wrong frame formulation and to information that is useless for poison centres.
  • Assuming the CPNP covers the UK: Great Britain needs its own SCPN notification and UK Responsible Person.
  • An address that differs from the label: creates inconsistencies that surface at the first inspection.

How we handle it

When you manufacture with us, we do the CPNP notification. EU documentation is prepared with our in-house expertise and external regulatory experts, in parallel with the PIF and the label. It is one of the six phases of our method, regulatory approval, described in how we work. Details of the service are on our EU and UK compliance page.

To sell outside the EU, we work with specialist partners: SCPN and UK Responsible Person for the United Kingdom, and support for Canada, the USA, Mexico and Australia.

Frequently asked questions

How much does CPNP notification cost?

Using the CPNP portal is free. Any costs relate to the work of preparing the data and the linked documents, such as the PIF and the label.

Who must submit the CPNP notification?

The Responsible Person, the party established in the EU who answers for the product’s compliance. They can delegate data entry in the portal, for example to the manufacturer.

Do I need to notify in every EU country?

No. One notification covers all Member States. The United Kingdom has a separate system, SCPN, with its own UK Responsible Person.

Is my product approved once it is notified?

No. The notification passes product data to the authorities, but it is not an authorisation. Safety is demonstrated by the PIF and the safety assessment.

Do I need to notify again if I change the formula?

A change to the formula must be reported by updating the information in the portal. If the change effectively creates a different product, a new notification may be needed: this is assessed case by case.

How long does it take to notify a cosmetic product?

Entering the data is quick once everything is ready. The real work is preparing the formula, label and documents, so we build it into the project schedule.

Documents ready before production

Formula, label, PIF and notification: we take care of them, with one project manager following you from the first call to delivery. Tell us about your project: we reply within one hour.

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Keep reading

  • EU and UK complianceEU cosmetics compliance handled for you: CPNP notification, PIF and safety report with regulatory experts, EU and UK Responsible Person via partners.
  • Product Information FileProduct Information File for cosmetics: what the PIF contains, who prepares it, where it is kept and for how long. A guide to Article 11 and Annex I.
  • EU cosmetic labellingEU cosmetic labelling: Responsible Person, nominal content, PAO, batch, INCI, label languages, small packs and UK labels. With the most common mistakes.
  • How we workHow to start a cosmetic line in 6 phases, from assessment to delivery: a dedicated project manager, samples before ordering, 4–6 weeks.