Every cosmetic product sold in the EU has to be notified in the Cosmetic Products Notification Portal (CPNP) before it reaches the market. The European Commission runs the portal, and notification is free. There is no approval step and no certificate at the end. Once a product is in the CPNP, you do not notify it again in each EU country.
The form itself is not the hard part. In our EU Responsible Person service for cosmetics, the CPNP notification is included and we submit it ourselves, but only after we have reviewed the Product Information File and the final label. That is not caution for its own sake. Almost every field in the notification depends on information that only exists once the formula, the safety report and the packaging are final.
What the CPNP is and what it is not
The CPNP is the online system set up to carry out Article 13 of Regulation (EC) No 1223/2009. Responsible Persons and distributors submit information in it, and national authorities and poison centres read it. The authorities use it for market surveillance, and poison centres use it to treat people in an emergency (Article 13(5) and 13(6)). A notification counts for the whole EU, and the same portal is used for the EEA countries, so you do not file anything extra at national level.
What the CPNP does not do is check your product. Nobody reviews the notification before you start selling, and you will not receive a CPNP certificate. What you get is a CPNP reference number for each product. The legal responsibility for the product stays with the Responsible Person, which is exactly why a serious Responsible Person checks the file before it notifies anything in its own name.
The CPNP also stops at the EU border. Great Britain has its own portal, Submit Cosmetic Product Notifications (SCPN), with its own requirement for a Responsible Person established in the UK. Northern Ireland follows a separate process.
Who submits a CPNP notification
The notification is made by the Responsible Person (Article 13(1)). If you are a brand outside the EU, that is the importer by default (Article 4(5)), or the person in the EU you appoint by written mandate. In practice the Responsible Person submits it from its own CPNP account, which needs an EU Login and access for its organisation.
Distributors have a smaller role. A distributor who makes a product available in another Member State and translates part of the label for that market has to submit its own short notification (Article 13(3)). It does that by finding the Responsible Person's notification in the CPNP and adding the Member State and the translated product name.
Based outside the EU? Our EU Responsible Person service for cosmetics includes the CPNP notification for every product in your range.
What goes into a CPNP notification
Article 13(1) lists what the Responsible Person must submit. The table shows each item and where the information usually comes from.
| What the CPNP asks for | Where it comes from |
|---|---|
| Product category and name | your product and label |
| Name and address of the Responsible Person where the PIF is available | the Responsible Person |
| Country of origin, for imported products | the manufacturer |
| Member State where the product is first placed on the market | your launch plan |
| Contact details of a person to call when needed | the Responsible Person |
| Presence of nanomaterials, with identity and exposure conditions | the formula and supplier data |
| Substances classified as CMR category 1A or 1B, with CAS or EC number | the formula and the safety assessor |
| Frame formulation for medical treatment | the formula |
On top of that, a photo of the original label and packaging has to be added at the latest when the product is placed on the market (Article 13(2)). A draft label will not do, because the photo has to match what is on sale.
Three ways to declare the formula
The CPNP user manual gives three options for the formulation, depending on the product category: a predefined frame formulation, exact concentrations, or concentration ranges. A predefined frame formulation only works if it covers the whole composition of your product. Ingredients are entered with their INCI names, and concentrations as percentages by weight, written with a decimal point (0.3, not 0,3). Your safety assessor already works with these figures, so the quickest route is to take them straight from the CPSR.
What the safety report itself must contain is explained in our article on the Cosmetic Product Safety Report.
Products with nanomaterials: notify six months earlier
If your product contains a nanomaterial, there is a second notification. Under Article 16(3) it has to be submitted six months before the product is placed on the market, in addition to the normal notification. Article 16 does not apply to nanomaterials used as colorants, UV filters or preservatives that are regulated through the annexes (Article 16(2)).
For a launch plan, this is the CPNP rule with the biggest effect on the calendar. If a supplier switches to a nano grade of an ingredient, ask your safety assessor whether Article 16 applies before you fix a launch date.
Changes and corrections in a CPNP notification
A notification is not a one-off. Article 13(7) says that any change to the notified information must be updated without delay. The CPNP manual separates an update from a correction. An update reflects a real change, for example a new formula, and creates a new version. A correction fixes something that was entered wrongly, without the product itself changing.
That difference matters when a manufacturer changes a raw material supplier. If the composition changes, the notification needs an update, and the PIF and safety report need to be checked as well. A typo in the product name is a correction.
Why the CPNP notification comes last
Look at the table again: almost every line depends on the formula, the safety assessment or the final label. That is why the notification is the last administrative step before you sell, not the first. We explain the full order in our article on the EU Responsible Person for cosmetics, from safety report to label.
Notifying early with a draft label or an unfinished formula does not save time. It means an update or a correction later, and a gap between what the authorities see and what is on the shelf.
Your checklist before a CPNP notification
- Make sure the Product Information File is complete, with a signed Cosmetic Product Safety Report.
- Have the final formula ready, with INCI names and percentages by weight.
- Check with your safety assessor for nanomaterials and CMR substances, and plan six extra months if Article 16 applies.
- Finish the label and packaging, with the Responsible Person's name and address on it, and take clear photos.
- Decide in which Member State you will start selling.
- Let the Responsible Person submit the notification, and keep the CPNP reference number with your product records.
- If a distributor translates your label for another country, tell them to add their own distributor notification.
Conclusion
A CPNP notification is free, quick to fill in and valid for the whole EU, but it is not an approval and it does not replace the safety work behind it. Everything the form asks for comes from the PIF, the safety report and the final label. Settle those first, and the notification takes little time.
We submit the CPNP notification for cosmetics brands from outside the EU as part of one annual Responsible Person service, after we have reviewed your file. View the service and send us your file.
Sources
- Regulation (EC) No 1223/2009 on cosmetic products, consolidated version, Articles 4, 13 and 16. EUR-Lex.
- European Commission, Cosmetic Products Notification Portal (CPNP), information page.
- European Commission, Guide to using CPNP for Responsible Persons and distributors, last updated 24 May 2017.
- UK Government, Submit a cosmetic product notification, guidance for Great Britain.
