Eu Cpnp Cosmetics Notification Service
A CPNP notification service is an execution assignment: prepare the correct product record, submit it through the European Commission portal under the correct responsible person (RP), and hand over a verifiable record. The portal itself is free; a provider’s charge is for professional work, not an EU registration tax.
Article 13 of Regulation (EC) No 1223/2009 requires the RP’s electronic notification before the cosmetic is first placed on the EU market. Notification is not an authorisation, safety approval or substitute for a cosmetic product safety report (CPSR), product information file (PIF), compliant label and other applicable obligations.
CPNP intake gate: cosmetic status, RP and safety dossier
Confirm the item is a cosmetic by its intended use and claims; medicinal, biocidal or medical-device claims may change the regulatory route. Before submitting, establish the EU-based RP and verify that the safety assessment/PIF and label route have been addressed. A portal entry cannot cure an unsafe or misclassified product.
If no EU responsible person has been identified, first determine whether the EU manufacturer, importer or an EU-based person designated and accepting the role in writing is the RP. An external paid RP appointment is not automatically necessary. A filing agent is not made the RP by entering portal data. Freeze the formula and label version before instructing the agent.
Article 13 filing: responsible person or distributor?
The filing account and legal duty depend on the supply chain, not on who pays an agency:
| Situation | Article 13 route | Service decision |
|---|---|---|
| EU manufacturer markets under its own brand | EU manufacturer normally acts as RP | File through RP access; verify the name on the label. |
| Imported cosmetic from outside the EU | Each EU importer normally becomes RP for its product, unless an EU person accepts designation by written mandate | Identify importer and RP before buying filing-only work. |
| Distributor independently translates existing EU label to comply with national law | Limited distributor notification under Article 13(3), alongside the RP framework | Do not confuse this with the RP’s initial notification. |
| Distributor rebrands or modifies the product so compliance may be affected | Distributor may become the RP under Article 4 | Reassess duties; a translation-only route may be wrong. |
| Product already notified by its RP | Check the existing filing, product identity and change history | Do not assume a second agency filing is necessary. |
For Article 13(3), the product must already have been placed on the market in another Member State, and the distributor must make it available in a further Member State after independently translating the label to comply with national law. Ordinary resale or mere translation without these facts does not establish that route.
The CPNP is not a public product-approval or lookup register. Ask the RP or its authorised portal operator to demonstrate the actual accessible record and its scope; a supplier-provided number or screenshot alone does not establish coverage of your brand, formula or RP.
CPNP input dossier: data needed for the filing
Request a product-by-product intake sheet, not just an INCI ingredient list:
- Commercial product name(s), product category, function, intended users and launch Member State; identify all names and versions precisely.
- RP legal name, EU address where the PIF is accessible, authorised portal access and a named physical contact for urgent questions.
- Country of origin if imported; clarify importers, brand owner and any existing product notification.
- For the distinct Article 13(3) distributor route: name and category in both the dispatch and destination Member States, the destination Member State, the distributor’s own name and address, and the RP’s name and address where the PIF is accessible.
- Composition information sufficient to create the required frame formulation for medical response, plus INCI/full formulation evidence for validation; flag category 1A/1B CMR substances where applicable.
- Nanomaterial identities and foreseeable exposure if present; screen separately for any additional Article 16 notification and its exceptions.
- Final original labelling and a photograph of the corresponding packaging where reasonably legible: Article 13(2) requires the RP to notify these when the cosmetic is placed on the market. Obtain the final files before launch; do not treat a missing photograph as a general exemption.
- Evidence that the CPSR, PIF, applicable ingredient restrictions and label compliance have been checked outside the portal, plus an SKU/variant and version register.
CPNP submission: five steps and stop points
Agree in writing which tasks the provider will perform and which decisions remain with the RP:
- Triage: confirm cosmetic classification, RP identity and whether a filing already exists; record missing evidence as blockers.
- Map: match each sellable product and relevant variant to its name, formulation, packaging and portal record; do not automatically collapse unlike formulas into one entry.
- Validate: compare intake data against the final formula, RP/PIF details, origin, intended Member State, special-ingredient flags and labels.
- Submit: for the RP notification, an agent must act on the RP’s authority; for the distinct Article 13(3) route, the distributor files in its own permitted portal role. Keep the reference and date. Submission does not prove legal conformity.
- Handover: provide the entered data, reference/confirmation, label version and unresolved exceptions; agree who updates the record when facts change.
Verify the CPNP record: provider handover checklist
Make these acceptance criteria contractual; a bare invoice saying “CPNP done” is not enough:
| Handover item | Acceptance check |
|---|---|
| Notification trace | Correct product/RP linked to portal reference, submission date and a retrievable record or confirmation. |
| Field reconciliation | Submitted product name, category, RP address, origin, market state, formulation flags and contact match approved input. |
| Label and variant trace | Final label/packaging version and covered shades or pack formats identified; any limitations written down. |
| Maintenance owner | RP or authorised operator named for corrections, updates and access; unresolved safety/PIF tasks remain explicit. |
For evidence, verify the record while logged in via the RP or authorised operator: CPNP is not a public searchable approval database.
CPNP amendments, shades and Article 16 nanomaterials
Before release, screen these cases rather than treating CPNP as permanent certification:
- Formula, product name, notified contact, RP details or other Article 13(1) information changes: review and update without delay under Article 13(7), and assess whether a distinct record is needed.
- A different shade, scent, kit component or packaging is introduced: check composition and portal coverage against the current Commission user guide; do not assume one SKU equals one notification or that all variants can be grouped.
- Nanomaterials: Article 16 may require a separate notification six months before marketing, subject to its specific exceptions; an ordinary Article 13 filing alone may be insufficient.
- A distributor only translates labelling across Member States: test the narrow Article 13(3) condition rather than commissioning a fresh RP filing automatically.
- A new RP, importer or brand arrangement, or sales outside the EU, can require a different responsibility/territory review; CPNP is not a Great Britain notification.
CPNP service quote: separate filing from RP and CPSR/PIF
Request a quote with a stated product/variant count, review assumptions and acceptance deliverables:
- Show filing labour separately from RP appointment, CPSR/PIF creation, testing, formulation review, translation and label corrections. The European Commission does not charge to use CPNP.
- Define who can edit the portal record after handover, how many corrections are included, and what happens if the RP changes; no universal official processing time or fixed provider fee should be promised.
- Do not launch merely because a reference appears. Confirm the other substantive cosmetics obligations and any special nanomaterial timing first.
Practical next action: send the provider a list of product names and versions, the RP/importer arrangement, final formulation and label files, existing CPNP references if any, planned first Member State and launch date. Ask for a written scope stating the correct Article 13 role, excluded CPSR/PIF work and the submission evidence to be returned.
Official sources
Primary legal and procedural references (check the latest consolidated Regulation and current portal user guide):
CPNP notification service: specific questions
Can a filing agent notify under its own company if it is not the RP?
The agent may operate on behalf of the authorised RP, but merely typing the entry does not transfer Article 4–5 legal duties. Establish the RP and access permissions before submission.
My supplier has a CPNP number. Can I reuse it for my private label?
Not automatically. Match the actual RP, brand/name, composition, label, importer structure and notified record. A different RP or changed product may require new work.
Can five shades be submitted as one product?
Sometimes the portal permits grouping only if the notification adequately covers every variant. Review formulation differences and the current Commission manual; neither five SKUs nor one base formula alone answers the question.
Does a label translation in another EU country require a new notification?
Only where an already-marketed cosmetic moves from one Member State to another and a distributor independently translates its labelling to comply with national law may Article 13(3) require the distributor’s limited notification. This is not a second full RP notification.
Does the CPNP reference prove my cream is approved or safe?
No. CPNP is an information notification, not a Commission product approval. CPSR, PIF, legal ingredients, labelling and the RP’s continuing duties remain relevant.