CPNP Cosmetic Notification: Step-by-Step Registration Guide
How to notify a cosmetic product through the EU CPNP portal. Step-by-step guide covering registration, required information, common errors, and timelines.
Key Takeaway
How to notify a cosmetic product through the EU CPNP portal. Step-by-step guide covering registration, required information, common errors, and timelines.
The Cosmetic Products Notification Portal (CPNP) is the EUβs centralised system for notifying cosmetic products before they are placed on the market. Every cosmetic product sold in the EU must be notified through CPNP by the Responsible Person before it reaches consumers. No notification, no legal market access β itβs that straightforward.
Yet CPNP notifications are a consistent source of delays and errors for brands new to the EU market. The portal has specific data requirements, some of which are not intuitive, and errors in the notification can create compliance gaps that surface during market surveillance inspections.
What Is the CPNP and Why Does It Exist?
The Cosmetic Products Notification Portal (CPNP) is an online system managed by the European Commission. It was established under EU Cosmetics Regulation (EC) No 1223/2009 to replace the previous national notification systems that existed in individual EU member states.
Before CPNP, a brand selling in 10 EU countries had to submit 10 separate national notifications. CPNP centralised this into a single notification that covers all EU member states simultaneously. It also provides poison centres across the EU with access to product formulation data β enabling faster and more accurate treatment of cosmetic-related poisoning cases.
The CPNP serves two functions:
- Market access notification: Confirms the product is being placed on the EU market by an identified Responsible Person
- Poison centre information: Provides emergency responders with formula data for medical treatment purposes
Who Can Submit a CPNP Notification?
Only the Responsible Person can submit a CPNP notification. The Responsible Person must be established in the EU and must have a CPNP user account.
Non-EU manufacturers cannot submit CPNP notifications directly. They must work through their EU Responsible Person, who submits the notification on their behalf.
If you are a non-EU brand without an EU Responsible Person, you cannot complete a CPNP notification. Appointing a Responsible Person is the prerequisite step.
Step-by-Step: How to Submit a CPNP Notification
Step 1: Create a CPNP Account
Go to the CPNP portal at cpnp.ec.europa.eu. The Responsible Person must register for an account using their EU business details. Account creation requires:
- Business name and EU address
- Contact person details
- VAT number (recommended)
Account approval typically takes 1 to 3 business days.
Step 2: Prepare Your Product Data
Before starting the notification, gather all required information:
Product identification:
- Product name (as it appears on the label)
- Product category (from the CPNP category list β there are 24 categories including skin care, hair care, oral hygiene, etc.)
- Shade/variant (if applicable β each shade of a colour cosmetic is a separate notification)
Responsible Person details:
- Name and EU address of the Responsible Person
- Contact email for regulatory correspondence
Formula information:
- Either the full quantitative formula (all ingredients with INCI names and percentages) or the frame formulation (ingredient ranges within defined limits)
- Fragrance and flavour components (if applicable)
- Nanomaterial information (if the product contains nanomaterials as defined in Article 2 of the regulation)
- CMR substance information (if the product contains substances classified as carcinogenic, mutagenic, or reprotoxic under CLP Regulation)
Label:
- Image of the product label in its final form
Country of manufacture:
- For non-EU manufactured products
Step 3: Enter Product Information in CPNP
Log in to the CPNP portal and select βNew Notification.β Work through the notification form:
Section 1 β Product identification: Enter the product name, category, and shade/variant information.
Section 2 β Responsible Person: Confirm or enter the Responsible Personβs details.
Section 3 β Product formula: Enter the formula information. You can enter either:
- Full quantitative formula: all ingredients with exact percentages
- Frame formulation: ingredient ranges (e.g., βWater 40-60%β, βGlycerin 1-5%β)
The frame formulation option allows a single notification to cover minor formula variations without requiring a new notification for each change. However, the ranges must be realistic β a frame formulation that covers 0-100% for most ingredients will be flagged.
Section 4 β Label: Upload an image of the product label. The label must be in its final form, including all required information under Article 19 of the regulation.
Section 5 β Special information: Indicate whether the product contains nanomaterials, CMR substances, or is intended for use on children under 3 years old. These trigger additional requirements.
Step 4: Submit and Receive Confirmation
Once all sections are complete, submit the notification. The CPNP system generates a notification reference number immediately. There is no waiting period β the notification is effective upon submission.
Keep the notification reference number. You may need it for customs documentation, retailer onboarding, or competent authority inquiries.
Step 5: Update the Notification When Required
CPNP notifications are not static. You must update the notification when:
- The formula changes (ingredient addition, removal, or concentration change outside the frame formulation range)
- The label changes (new claims, new warnings, new Responsible Person)
- The Responsible Person changes
- The product is discontinued (you must notify discontinuation)
Failure to update the CPNP notification when the product changes is a compliance gap that can surface during market surveillance inspections.
Common CPNP Notification Errors
Wrong product category: CPNP has 24 product categories, and some products fit multiple categories. Choosing the wrong category can affect which regulatory requirements apply. If in doubt, choose the most specific applicable category.
Incomplete formula: The most common error. The formula must include all ingredients, including water, preservatives, fragrances (by INCI name), and colorants. Omitting ingredients β even minor ones β creates a compliance gap.
Label not in final form: Uploading a draft label or a label missing required information (e.g., missing PAO symbol, missing Responsible Person address) creates a notification that doesnβt match the product as sold.
Missing nanomaterial declaration: Products containing nanomaterials (as defined in Article 2 of the regulation) require specific nanomaterial notification under Article 16. Failing to flag nanomaterials in the CPNP notification is a regulatory violation.
Not updating after formula changes: Brands that reformulate products without updating the CPNP notification are non-compliant. The CPNP notification must reflect the product as currently manufactured.
CPNP Notification for Multiple EU Countries
A single CPNP notification covers all EU member states. You do not need separate notifications for France, Germany, Italy, etc. However, some member states have additional national requirements:
- France: DGCCRF requires a separate national notification for food supplements (not cosmetics, but relevant for borderline products)
- Germany: BfR (Federal Institute for Risk Assessment) has specific requirements for certain cosmetic product categories
For purely cosmetic products, the single CPNP notification is sufficient for all EU member states.
Timelines
CPNP notification is effective immediately upon submission. There is no review period or approval process β the notification is a declaration, not an application. Products can be placed on the EU market immediately after notification submission, provided all other compliance requirements (CPSR, PIF, label compliance, GMP) are met.
CPNP notification is the administrative gateway to the EU cosmetic market. Itβs not technically complex, but it requires complete and accurate product data. Brands that invest time in getting the notification right β complete formula, final label, correct category β avoid the compliance gaps that create problems during market surveillance.
At Care Europe, we manage CPNP notifications for brands entering the EU market as part of our Responsible Person service. Contact us at [email protected].
Written by
Nour AbochamaQuality & Regulatory Advisor, Care Europe | VP Operations, Qalitex
Chemical engineer with 17+ years of experience in laboratory operations, quality assurance, and regulatory compliance across Europe and North America. VP of Operations at Qalitex (ISO/IEC 17025 accredited laboratory). Expert in GMP compliance, ISO 17025 quality systems, EU cosmetics regulation, and export requirements for the USA and Canadian markets. Based in Europe with deep knowledge of French and EU regulatory frameworks.
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