CPNP: how a cosmetic product is notified before it goes on sale in the EU

The CPNP, the Cosmetic Products Notification Portal, is the European Commission’s online system for the notification that the EU Cosmetics Regulation, Regulation (EC) No 1223/2009Regulation (EC) No 1223/2009, Cosmetic Products RegulationThe whole regulationClick opens the law on the EU Publications Office., requires for every cosmetic product before it goes on sale (Art. 13(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.). The notification is not an approval, and the Regulation sets no waiting period after it, except for products with nanomaterials.

What the CPNP is

The Commission describes the CPNP as “a free of charge online notification system created for the implementation of Regulation (EC) No 1223/2009Regulation (EC) No 1223/2009, Cosmetic Products RegulationThe whole regulationClick opens the law on the EU Publications Office. on cosmetic products”. When a product has been notified there, “there is no need for any further notification at national level within the EU” (European Commission, CPNP). The portal is at webgate.ec.europa.eu/cpnp.

The Commission passes the information on, without delay, to two kinds of reader:

• the national competent authorities, which may use it only for market surveillance, market analysis, evaluation and consumer information (Art. 13(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 5Click opens the article on EUR-Lex.);
• the poison centres the EU countries have set up, which may use it only for medical treatment (Art. 13(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 6Click opens the article on EUR-Lex.).

The authorities see everything except the frame formulation; the poison centres see all of it (Art. 13(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 5Click opens the article on EUR-Lex., Art. 13(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 6Click opens the article on EUR-Lex.). The portal is open to authorities, poison centres, responsible persons and distributors, not to the public (European Commission, CPNP).

A successful notification does not mean the product complies. The Commission’s user guide says so in as many words: notification “does not imply that the product in question fulfills all the requirements” of the Regulation (CPNP user guide, section 1.1). The safety report, the product information file and the label are separate duties, set out in the EU Cosmetics Regulation guide.

Who notifies a cosmetic product

The notification of Art. 13(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex. is the responsible person’s duty, and the responsible person is a person or company established in the EU (Art. 4(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 5(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 5, paragraph 1Click opens the article on EUR-Lex.). Who that is depends on where the product is made and who brings it in:

In the portal, the account belongs to the responsible person’s organisation; staff and others “acting on their behalf” are users of it (CPNP user guide, “Intended audience”). The responsible person’s name and address in the notification are taken from that account, so they must match the label exactly (CPNP user guide, section 1.2). Who can be your responsible person, and what the role involves, is in EU cosmetics responsible person.

What goes into a CPNP notification

Before the product is placed on the market, the responsible person submits by electronic means (Art. 13(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.):

The portal also asks whether the product is meant specifically for children under three, its physical form, and whether it comes in a special applicator (CPNP user guide, section 3.1.1). “Original” labelling means the label of the first placing on the EU market, and it is due at the latest when the product goes on sale (CPNP user guide, section 3.1.1). A notification can be saved as a draft. Once you click Notify, it goes to the authorities and poison centres, and it can no longer be deleted, only updated (CPNP user guide, section 3.1.1). Each product gets a CPNP reference, the number by which it is found in the portal (CPNP user guide, section 3.1.7).

How to get into the portal

1. Create an EU Login account, the Commission’s sign-in service, with your email address and a password (CPNP user guide, section 2.1).
2. Create a SAAS account, the authorisation system of the Commission’s health directorate, with a role in an active organisation and a CPNP profile, at webgate.ec.europa.eu/saas. The first person to create the organisation becomes its Local Administrator and accepts everyone else who asks to join it (CPNP user guide, sections 1.2 and 2.1).
3. Sign in at webgate.ec.europa.eu/cpnp with the EU Login email address and password (CPNP user guide, section 2.2).

If the organisation’s name or country is later changed in SAAS, the CPNP turns read-only for it until the Local Administrator gives the reason for the change (CPNP user guide, section 2.3.2).

The CPNP is free of charge

The Commission charges nothing for a notification (European Commission, CPNP), and one notification covers every EU country. What costs money is the work around it: the responsible person, the safety assessment and the product information file.

Frame formulation, exact concentrations or ranges

A frame formulation “lists the category or function of ingredients and their maximum concentration in the cosmetic product”, or gives the relevant quantitative and qualitative information where a product is not covered by such a formulation (Art. 2(1)(s)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 2, paragraph 1, point (s)Click opens the article on EUR-Lex.). It is in the notification so that a poison centre can treat someone quickly (Art. 13(1)(h)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1, point (h)Click opens the article on EUR-Lex.).

The portal gives three ways to declare the composition (CPNP user guide, section 3.1.1):

• Predefined frame formulation. An expert group of poison centres, authorities, industry and the Commission wrote a set of frame formulations; the portal suggests one from the category you chose. You may use it only if the whole composition falls inside its ranges. If any ingredient is above its maximum, or not covered at all, you may not use it.
• Exact concentrations. Every ingredient with its concentration, in % w/w.
• Concentration ranges. Every ingredient within the ranges the portal allows.

Whichever you choose, the portal asks about specific ingredients of concern, such as ethanol and isopropanol, and for some categories the pH, which is given as a range of no more than one unit (CPNP user guide, section 3.1.1 and Appendix). Ingredient names are INCI names where one exists.

Products with nanomaterials: the six-month notification

A nanomaterial is “an insoluble or biopersistant and intentionally manufactured material with one or more external dimensions, or an internal structure, on the scale from 1 to 100 nm” (Art. 2(1)(k)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 2, paragraph 1, point (k)Click opens the article on EUR-Lex.). A product containing one goes through two notifications:

1. The ordinary notification, which names the nanomaterial and its exposure conditions (Art. 13(1)(f)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1, point (f)Click opens the article on EUR-Lex.).
2. A separate notification in the CPNP’s nanomaterial module, six months before the product is placed on the market (Art. 16(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.). It gives the nanomaterial’s identity, its specification including particle size, the estimated quantity placed on the market per year, its toxicological profile, its safety data for that product category, and the foreseeable exposure.

The six-month notification does not apply to a nanomaterial used as a colorant, preservative or UV filter regulated under Art. 14Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 14Click opens the article on EUR-Lex. (Art. 16(2)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex.), nor to a product whose nanomaterials meet the requirements of Annex III (Art. 16(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex., third subparagraph). The responsible person may give the nanomaterial notification to someone else by written mandate, and tells the Commission (Art. 16(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.). In the portal that person is a “Delegate for nanomaterials”, who cannot file the ordinary notification (CPNP user guide, section 1.2).

CMR substances in the notification

The notification names every substance in the product that is classified as carcinogenic, mutagenic or toxic for reproduction, category 1A or 1B, under the CLP Regulation, with its CAS or EC number (Art. 13(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1, point (g)Click opens the article on EUR-Lex.). Those substances are banned in cosmetics, with narrow exceptions the Commission grants by listing them in the annexes after a safety evaluation (Art. 15(2)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 15, paragraph 2Click opens the article on EUR-Lex.). A product with none answers “no” in the portal (CPNP user guide, section 3.1.1).

When a distributor notifies

A distributor is anyone in the supply chain other than the manufacturer or the importer who makes the product available in the EU (Art. 2(1)(e)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 2, paragraph 1, point (e)Click opens the article on EUR-Lex.). A distributor notifies only in one case: it makes the product available in an EU country, after the product was placed on the market in another, and translates any part of its label on its own initiative to meet that country’s law (Art. 13(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 3Click opens the article on EUR-Lex.). It then submits:

• the category of the product, its name in the country of dispatch and its name in the country where it is made available;
• the EU country where it is made available;
• its own name and address;
• the name and address of the responsible person where the product information file is kept.

In the portal, the distributor finds the product by its CPNP reference and links its entry to the responsible person’s notification, so the responsible person must have notified the product first (CPNP user guide, sections 1.2 and 3.4). Translating a label does not make the distributor the responsible person (Art. 4(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 4, paragraph 6Click opens the article on EUR-Lex., second subparagraph). Selling under its own name or brand does, and then it files the full notification (Art. 4(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 4, paragraph 6Click opens the article on EUR-Lex.).

When you notify again or update

Where any of the information of Art. 13(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex., (3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 3Click opens the article on EUR-Lex. or (4)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 4Click opens the article on EUR-Lex. changes, the responsible person or the distributor updates it without delay (Art. 13(7)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 7Click opens the article on EUR-Lex.). In practice:

When you edit a notification, the portal asks whether the change is an update (the real formula changed) or a correction (the data was wrong, the formula was not). Only an update of the formulation or category creates a new version, and a poison centre then weighs both formulas when it cannot tell which one a patient used (CPNP user guide, section 3.1.2).

Who owes what

What happens if you do not notify

The notification requirements of Art. 13Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13Click opens the article on EUR-Lex. and Art. 16Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16Click opens the article on EUR-Lex. are on the list of failings for which the authority requires the responsible person to bring the product into conformity, withdraw it or recall it, within a time limit it sets (Art. 25(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex., point (e)), and for every unit made available anywhere in the EU (Art. 25(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 25, paragraph 3Click opens the article on EUR-Lex.). If the responsible person does not act in time, the authority itself prohibits, restricts, withdraws or recalls the product (Art. 25(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 25, paragraph 5Click opens the article on EUR-Lex.). A distributor faces the same demands when it breaks its duties of care under Art. 6Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 6Click opens the article on EUR-Lex. (Art. 26Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 26Click opens the article on EUR-Lex.); that list does not include its own notification of Art. 13(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 3Click opens the article on EUR-Lex.. Each EU country sets the penalties for any breach of the Regulation, a missed notification included, and they must be effective, proportionate and dissuasive (Art. 37Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 37Click opens the article on EUR-Lex.).

The UK: SCPN for Great Britain, the CPNP for Northern Ireland

Great Britain (England, Scotland and Wales) replaced the CPNP with its own service (GOV.UK, Great Britain guidance). A cosmetic product made available to consumers there is notified to the Office for Product Safety and Standards in the UK’s Submit cosmetic product notifications service, SCPN (GOV.UK). The UK text of Article 13 asks for the same information as the EU one, without the country of origin and the country of first sale, sent to the Secretary of State: category and name, the responsible person, the address of the product information file, an emergency contact, nanomaterials, CMR substances and the frame formulation, then the original label and a photograph of the packaging when the product goes on sale. Any change is updated without delay.

How it differs from the CPNP:

• A UK responsible person. The responsible person for Great Britain must be established in the UK; a mail forwarding or PO box address does not count (GOV.UK). An EU responsible person cannot notify in SCPN.
• GOV.UK One Login, not EU Login, to sign in (SCPN).
• Nanomaterials. A product with a nanomaterial not used as a colorant, preservative or UV filter is notified in SCPN six months before it goes on sale in Great Britain (GOV.UK, Great Britain guidance, paragraphs 51 and 66).
• The penalty is stated on the service itself: “You may face a fine and a prison term of up to 3 months if you do not notify OPSS about a cosmetic product. This fine could be unlimited in England and Wales or up to £5,000 in Scotland and Northern Ireland” (SCPN).

The gov.uk pages for SCPN name no fee.

Northern Ireland follows the EU Regulation. There “the Responsible Person must be established in NI or the EU” (GOV.UK), so one based in Great Britain cannot do it. A product placed on the market there is notified in the CPNP. If the same product is also sold in Great Britain, it is notified in SCPN as well (GOV.UK, Northern Ireland guidance, paragraphs 54 and 55).

Selling to both the EU and Great Britain, each product is therefore notified twice: in the CPNP by its responsible person in the EU, and in SCPN by its responsible person in the UK.

What is agreed but not yet law

On 8 July 2025 the Commission proposed deleting the six-month nanomaterial notification of Art. 16(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex., so that a product with nanomaterials is notified once, like any other, and the nanomaterial data goes into the safety report instead (recital 23 and point (3) of the article amending the Cosmetics Regulation in COM(2025) 531). Parliament and Council negotiators reached a political agreement on 16 June 2026. It still awaits the legal-linguistic revision, formal adoption and publication in the Official Journal, and it reinstated notification for nanomaterials in cosmetics, which the proposal would have deleted (European Parliament Legislative Train). Until the amending act is published, the consolidated text of 18 May 2026 applies as it stands, and it still contains Art. 16(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex..

What the law leaves open

• Whether a label-only change is notified again. The update duty covers the information of Art. 13(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex., (3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 3Click opens the article on EUR-Lex. and (4)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 4Click opens the article on EUR-Lex. (Art. 13(7)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 7Click opens the article on EUR-Lex.). The original label and pack photograph are notified under Art. 13(2)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 13, paragraph 2Click opens the article on EUR-Lex., which that list does not name. One example is a label that now names more EU fragrance allergens. Meanwhile: upload the new label whenever the label changes.
• What happens when the old responsible person will not copy the products. The Regulation sets no procedure for a change of responsible person; the copy function in the portal is run from the old responsible person’s account (CPNP user guide, section 3.1.4). The new responsible person must still ensure the notification for every product it places on the market (Art. 4(2)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex., Art. 5(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 5, paragraph 1Click opens the article on EUR-Lex.). Meanwhile: the new responsible person notifies the products itself, with its own details, before it takes them over.

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