What is cosmetic product notification?
The Cosmetic Products Notification Portal (CPNP) is an EU-wide online system where all cosmetic products must be registered before being marketed. This process ensures transparency and accessibility for EU authorities, poison centres, and control bodies.
Before placing a cosmetic product on the EU market, companies must complete the Cosmetic Product Notification, as required under EU Regulation (EC) No 1223/2009. Our CPNP Notification Service ensures full compliance, allowing your products to be legally sold within the European Union.
Who is required to submit a notification?
Cosmetic product notification must be carried out by the Responsible Person. The Responsible Person can be:
- Manufacturers established within the EU: If the cosmetic product is manufactured in the EU and is not exported and re-imported, the manufacturer is typically the Responsible Person.
- Importers from outside the EU: If the product is manufactured outside the EU, the importer placing the product on the EU market for the first time is considered the Responsible Person. However, the importer may appoint another natural or legal entity established in the EU as the Responsible Person through a written mandate.
- Distributors: A distributor becomes the Responsible Person if they place a product on the market under their own name or trademark or modify a product already on the market in a way that affects its compliance.
- Authorized third parties: In other scenarios, a manufacturer, importer, or distributor may appoint a third party or consulting firm based in the EU as the Responsible Person, provided that the role is formally accepted.
How does the cosmetic product notification process work?
The process can be summarized as follows:
- The responsible person is determined.
One of the entities listed above is designated as the Responsible Person. Only one Responsible Person may be appointed per product.
- Product information file (PIF) is prepared.
Before placing the product on the EU market, the Responsible Person must prepare a Product Information File (PIF) and store it at an easily accessible address. Chemleg can assist in preparing the PIF and the Cosmetic Product Safety Report (CPSR) within it.
- The product is registered in the CPNP system.
The Responsible Person must register the product via the European Commission’s Cosmetic Products Notification Portal (CPNP).
- Cosmetic product notification is made.
After registration, the necessary product details must be uploaded to the CPNP system, including:
- Product category and name
- Name and address of the Responsible Person
- Address where the PIF is readily accessible
- Country of origin if the product is imported
- EU Member States where the product will be marketed
- Contact details of a natural person (if required)
- For products containing nanomaterials: identification, characteristics, estimated annual quantity, toxicological profile, and foreseeable exposure conditions
- For products containing CMR substances (Carcinogenic, Mutagenic, or Reproductive toxins): substance name and CAS/EC numbers
- Product labelling and packaging information
- Product formulation (either frame formulation or full formulation)
- Labelling and packaging operations are carried out.
The product’s label and packaging must include all mandatory information specified in Article 19 of the EU Cosmetics Regulation.
- Market surveillance and cosmetovigilance should be conducted.
National authorities may inspect products to ensure compliance and request to review the PIF. The Responsible Person must monitor and report any serious undesirable effects associated with the product to the competent authorities without delay.
How does Chemleg support your cosmetic product notification?
With its expert team, Chemleg helps ensure a smooth and successful notification process, avoiding delays and ensuring full regulatory compliance. Our Cosmetic Product Notification Service includes:
- Product Information File Collection
- Cosmetic Product Safety Report (CPSR) Verification
- Responsible Person (RP) Registration
- Product Notification Submission to CPNP
- Labelling & Claims Compliance Review
- Confirmation & Compliance Documentation
- Good Manufacturing Practices (GMP) Compliance Support (ISO 22716 guidance)
You can contact our experts by filling out the form.
Frequently Asked Questions
What is the purpose of CPNP?
The main purposes of cosmetic product notification include ensuring consumer safety, improving market surveillance and control, facilitating the notification process, and enhancing transparency and information exchange.
What happens if the product is not notified?
Notification is mandatory for marketing cosmetic products in the EU. Products that are not notified or are incompletely notified may be subject to fines, product recalls, or bans on market access within the EU.
What information is needed for notification?
Generally, the required information includes product category and name, contact details of the Responsible Person, PIF address, country of origin, EU countries where the product will be sold, formulation details, and additional data if nanomaterials or CMR substances are present, along with product labelling information.
Do my responsibilities end after notification?
No. Even after notification, the Responsible Person remains accountable for: keeping the PIF up to date, ensuring ongoing product safety, maintaining GMP compliance, keeping labelling requirements current, and monitoring/reporting serious undesirable effects to the authorities.
What if my product formulation changes?
If there are changes in the product formulation or any other information in the notification, the CPNP entry must be updated. Keeping the notification current is crucial.
Does EU cosmetics regulation apply only to products made in the EU?
No. The EU Cosmetics Regulation applies to all cosmetic products placed on the EU market, regardless of whether they are produced within the EU or imported from outside.
