CPNP notification is one of the mandatory requirements established by Regulation (EC) No 1223/2009 for cosmetic products placed on the European Union market.

The CPNP – Cosmetic Products Notification Portal is the European online portal through which information on cosmetic products is submitted before they are placed on the market.

CPNP notification is not a marketing authorisation. However, it is an essential regulatory obligation that allows competent authorities and poison centres to access the necessary information on cosmetic products.

When Is CPNP Notification Required?

CPNP notification must be completed before the cosmetic product is placed on the market.

This obligation applies to:

• cosmetic products manufactured within the European Union;
• cosmetic products imported from non-EU countries;
• products marketed under a company’s own brand;
• products already placed on the EU market and distributed in another Member State with translated labelling, where required by the Regulation.

Article 13 of Regulation (EC) No 1223/2009 provides for notification obligations both for the Responsible Person and, in specific cases, for the distributor.

Notification by the Responsible Person

In most cases, CPNP notification is carried out by the Responsible Person.

The Responsible Person is the natural or legal person established within the European Union who ensures that the cosmetic product complies with Regulation (EC) No 1223/2009.

Before placing the product on the market, the Responsible Person must ensure that the product is correctly:

• assessed for safety;
• documented through the PIF;
• compliant in terms of formulation;
• labelled;
• notified through the CPNP.

The CPNP notification must be consistent with the formulation, label, product category, PIF and Responsible Person data.

Notification by the Distributor

In some cases, the distributor may also be required to submit a CPNP notification.

This may occur when a distributor makes available in one Member State a cosmetic product already placed on the market in another Member State and, on their own initiative, translates elements of the label in order to comply with the language requirements of the destination country.

In these cases, the distributor must submit the required information through the CPNP, ensuring that the product information is correctly available in the market where the product is distributed.

What Is the Purpose of CPNP Notification?

CPNP notification plays an essential role in the European cosmetic product surveillance system.

The information submitted through the portal is made electronically available to:

• competent authorities, for market surveillance, analysis, evaluation and consumer information;
• poison centres or similar bodies established by Member States, for medical treatment purposes.

The notification therefore contributes to consumer health protection and allows competent bodies to quickly access relevant product information when needed.

What Information Is Entered in the CPNP?

The notification requires the submission of specific information on the cosmetic product.

The main information may include:

• cosmetic product category;
• product name;
• Responsible Person data;
• country of origin, in the case of imported products;
• Member State of first placing on the market;
• contact details of a natural person;
• presence of nanomaterials, where applicable;
• presence of CMR substances, where applicable;
• frame formulation or information useful for medical treatment;
• original label;
• packaging image, where required or useful for product identification.

The quality of the information entered is very important, as the notification must correctly represent the product actually placed on the market.

CPNP, PIF and Label: Connected Documents

CPNP notification should not be considered an isolated requirement.

It must be consistent with:

• qualitative and quantitative formula;
• PIF – Product Information File;
• Cosmetic Product Safety Report;
• label;
• claims;
• cosmetic product category;
• Responsible Person data;
• available tests;
• technical documentation of the product.

An outdated notification or one that is not consistent with the actual product may represent a regulatory issue.

For example, changes to the formula, label, product name, Responsible Person, packaging or presence of specific ingredients may require the notification to be updated.

CPNP Notification Does Not Replace the PIF

It is important to clarify that CPNP notification does not replace the PIF and does not replace the safety assessment.

Before notifying a cosmetic product, the technical documentation must be properly prepared.

In particular, the product should be supported by:

• complete formulation;
• safety assessment;
• Cosmetic Product Safety Report;
• PIF;
• compliant label;
• raw material documentation;
• any necessary tests;
• claims assessment.

The notification is therefore a final step in the regulatory process and should be completed when the product is ready to be placed on the market.

Common Errors in CPNP Notification

The most common errors in CPNP notification management include:

• notification submitted before the PIF is complete;
• data not consistent with the label;
• incorrect cosmetic product category;
• formula or frame formulation not updated;
• incorrect Responsible Person data;
• failure to update the notification after product changes;
• uploaded labels not matching the marketed version;
• failure to assess nanomaterials or substances subject to specific obligations;
• confusion between CPNP notification and marketing authorisation.

Proper CPNP management helps avoid documentation inconsistencies and issues in case of inspection.

Support for CPNP Notification

Support for CPNP notification may include:

• company registration through EU Login;
• access and management of the CPNP profile;
• preliminary review of available documentation;
• consistency check between formula, PIF and label;
• entry of the required information in the portal;
• upload of label and required product information;
• update of existing notifications;
• management of changes relating to product, label or Responsible Person;
• support for products imported from non-EU countries;
• support for distributors in cases where notification is required by the Regulation.

An Essential Step for Placing Cosmetics on the EU Market

CPNP notification is a key step in placing a cosmetic product on the European Union market.

Although it is not a prior authorisation, it is an essential regulatory obligation and must be managed with accuracy, consistency and proper documentation.

A correct notification, aligned with the PIF, formula, label and Responsible Person data, helps reduce the risk of non-compliance and supports a more structured management of the cosmetic product on the European market.