CPNP notification step by step: what cosmetic brands need before they sell in the EU

Before a cosmetic product can be sold anywhere in the European Union, it has to be notified in the Cosmetic Products Notification Portal, the CPNP. It is free, it is online and it is often the last step before launch, which is exactly why it causes delays when the information is not ready.

What the CPNP is

The CPNP is the European Commission’s online notification system under the EU Cosmetics Regulation (Regulation (EC) No 1223/2009). One notification covers the whole EU: there is no need to notify again in each member state. National authorities and poison centres use the information for market surveillance and in medical emergencies.

Who has to notify

• The Responsible Person notifies every product before it is placed on the EU market (Article 13).
• A distributor has its own, shorter notification duty when it makes a product available in another member state and translates any part of the labelling on its own initiative.
• Products with nanomaterials that are not already regulated in the Annexes of the Regulation need a separate notification six months before they are placed on the market (Article 16).

What you need before you start

Article 13 of the Regulation lists what the notification must contain. In practice, prepare:

• the product category and the product name, exactly as on the label;
• the name and address of the Responsible Person, where the product information file is available;
• the country of origin, for imported products;
• the member state where the product is first placed on the market;
• the contact details of a person who can be reached if needed;
• the presence of nanomaterials, with their identification;
• any substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR, category 1A or 1B);
• the frame formulation or the exact formulation, so poison centres can act in an emergency;
• the original label and, where reasonably legible, a photograph of the packaging.

Step by step

1. Create an EU Login account and get access to the CPNP for your organisation as Responsible Person.
2. Make sure the safety assessment and the product information file are finished first. The CPNP is not the place to discover missing data.
3. Enter the product, its category, formulation and labelling, and upload the label and packaging images.
4. Submit. The product receives a CPNP reference number. Keep it in the product information file.
5. Update the notification whenever something relevant changes, such as the label, the formulation or the Responsible Person.

Common mistakes

• A product name in the CPNP that differs from the name on the label or on the marketplace.
• A Responsible Person in the CPNP that is not the one printed on the packaging.
• Notifying before the safety assessment is final, then changing the formulation without updating the notification.
• Assuming the CPNP also covers Great Britain. Since Brexit, products sold in Great Britain need a separate notification in the UK system.
• Forgetting that every shade or variant that is a different product needs its own notification.

Why marketplaces care

Amazon, bol, Kaufland and Galaxus increasingly ask for proof that a cosmetic product complies with EU rules, together with the product safety details required under the General Product Safety Regulation. A clean CPNP notification with matching names and Responsible Person details makes those checks quick.

KOD can act as your EU Responsible Person and handle the CPNP notification as part of an EU launch, together with labelling, marketplace compliance and stock in the Netherlands.

Sources: European Commission, Cosmetic Products Notification Portal; Regulation (EC) No 1223/2009, Articles 13 and 16. This article is general information and not legal or regulatory advice.