A Comprehensive Guide to the Cosmetic Product Notification Portal (CPNP)

As established by Article 13 of EU Regulation 1223/2009, before placing a cosmetic product on the European market, the responsible person must submit a series of details in electronic format to the European Commission. The Cosmetic Product Notification Portal (CPNP) is the European portal for the notification of cosmetic products, allowing the responsible person or their delegate to transmit all required product information directly.

The CPNP portal is shared across all member states of the European Union and, as such, contains the notification of all cosmetic products in free circulation on the European market.

CPNP Registration For Cosmetics: Obligations and Data Requirements

Registration with the CPNP for cosmetics must be carried out by the Person Responsible for placing the product on the European market, whose name and address are displayed on the product label.

The most important and necessary data for registering cosmetics on the European market to be transmitted to the CPNP are, briefly:

• The name of the product and the category of the cosmetic product must be clearly specified to ensure unique identification. The name should be stated exactly as it appears on the label, including the brand, product line, and specific name. This information must also make the product’s function immediately clear.
• The product label and a photo must be provided to ensure clear and unequivocal identification of the product.
• Name and address of the person responsible: as the holder of the product information file to be made available to the competent authorities upon request. 

It is important to remember that if a product is sold in different countries with a name that varies depending on the language of the sales market, each language version must be notified individually. If a product is imported into the European territory from a non-EU country, the importer automatically becomes the Responsible Person and is therefore required to register the cosmetic product on the CPNP.

The CPNP notification must be updated whenever any changes occur, such as a change in the product name, label design or trademark, packaging format, or if the Responsible Person changes.

The Details of The Information Transmitted to The CPNP Portal

Let’s examine this in detail: the information submitted to the CPNP portal must be precise and must clearly represent the product intended for sale without any ambiguity.

Specifically, the notification to the CPNP must include:

• the product name(s) by which the product can be identified;
• trademark, product line, and specific name including function;
• name and address of the responsible person;
• if the product is intended specifically for children under 3 years of age;
• the details of a natural person who can be contacted in an emergency;
• the country of origin in the case of foreign importation;
• Member State of the European Community of the first placing on the market;
• the presence in the product of nanomaterials or CMR substances (carcinogenic, mutagenic or toxic for reproduction);
• the framework formulation of the product, with which it is possible to recognize its category and the substances present (or the exact qualitative/quantitative composition);
• the packaging and label of the product.

Single-component or Multi-component Products

The notification to the CPNP may concern products with one or several components, in more detail: 

• Products with a single component: A “product with a single component” is a product that consists of a single element. 

Examples: a single jar of moisturizer, a single bottle of shampoo, a lipstick, a single bottle of aftershave lotion etc. 

• Multi-component products: A “multi-component product” is a product containing multiple components that are not marketed separately. 

Examples: hair coloring sets, skin exfoliation kits, perm products, anti-aging/revitalizing kits, etc.

Access to Transmitted Information: Who Can Verify It?

Access to the information submitted to carry out the CPNP verification is limited only to competent authorities for the purposes of market surveillance and market analysis. The Commission shall make the information immediately available to poison control centres or similar bodies duly set up by the Member States in order to identify the correct medical treatment in the event of adverse events.

What If I Am a Distributor?

From 11 January 2013, distributors who make a cosmetic product available in a Member State after it has already been placed on the market in another Member State and who translate any element of the product label must submit the following information to the European CPNP portal: 

(a) the category of the cosmetic product, its name in the Member State of dispatch, and its name in the Member State where it is being made available, ensuring clear identification; 

(b) the Member State where the cosmetic product is being made available.
c) the distributor’s name and address

In the case of distributors who import cosmetics from non-EU countries, the transmission of the notification is always necessary before the arrival of the goods at customs.

For the distributor, it is important to consider three possible scenarios:

1. If the distributor translates the label into the language of the Member State where the cosmetic product will be made available but makes no other changes, they must register with the CPNP as a distributor and notify the label, linking this notification to the one originally submitted by the Responsible Person for that cosmetic product.
2. If the distributor is designated as the Responsible Person, places the cosmetic product on the market under their own name or brand, or makes substantial changes to the label, they must register with the CPNP as a Responsible Person and submit a new notification. Substantial changes include modifications to the product name, usage instructions, or packaging.
3. If the distributor makes no changes to the label because it already includes the required language for the Member State where the cosmetic will be made available, no notification is required.

Notification Process Frequently Asked Questions

Which cosmetic products must be notified? 
The notification submission to the CPNP portal is mandatory for all cosmetic products.

Are there penalties for placing a cosmetic product on the market without prior notification to the CPNP by the Responsible Person?
Yes, substantial fines may apply, ranging from €1,000 to €6,000 for marketing a cosmetic product that has not been previously notified to the CPNP. These amounts are provided as examples and are based on the Sanctioning Regulations currently in force in Italy. Each member state, in accordance with European Regulation, must have its own law in place that specifies these amounts, which can vary from one state to another.

When should the cosmetic notification be sent to the European Cosmetics Portal CPNP?
Each cosmetic product must be notified to the CPNP before it is placed on the market (as described in the aforementioned Article 13 of Regulation (EC) 1223/2009). For cosmetics containing nanomaterials, however, it is specified that the notification must be sent six months before the product is placed on the market.

Does the notification of a cosmetic product need to be updated?
Yes, if a change is made to the name, formula, label or other aspect of the product, it is necessary to notify such changes by updating the notification originally sent.

Who must send the notification to the European Cosmetics Portal CPNP?
The transmission of the notification to the CPNP portal must be carried out by  the Responsible Person and the Distributor in the event that they translate the label into the language of the country where they will make the product available

Is there any communication after the notification is submitted?
No, no communication is sent following the notification to the CPNP. The registration of the product on the portal, as mentioned above, should not be considered as marketing approval. Therefore, even if the notification to the portal is completed successfully, it does not imply that the product complies with all the requirements of Regulation (EC) 1223/2009, which the Responsible Person must ensure.

Contact person: who is this?
For each cosmetic product notified to the CPNP, the Responsible Person must provide the details of a natural person to be contacted in case of need. This individual is referred to as the Contact Person.

Conclusion

Notification to the CPNP portal is just one of the many obligations that come with the lifecycle of a cosmetic product.

Contact us for expert advice to ensure all your products meet the required standards, covering areas such as notification to the portal, cosmetic PIF, formula compliance, and more.