The CPNP Portal — How to Notify a Cosmetic Product in the EU

Before a cosmetic product can legally be placed on the EU market, the Responsible Person must submit a notification through the Cosmetic Products Notification Portal — the CPNP. This is a mandatory pre-market step under Article 13 of Regulation (EC) No 1223/2009, and it is not a formality. The information submitted to the CPNP is used by poison centres across the EU to respond to accidental exposure incidents, and it is reviewed by competent authorities as part of market surveillance. Errors in the notification can create compliance gaps that are difficult to correct after the product is already on shelves.

This article is for regulatory affairs managers, quality directors, and brand owners preparing their first EU cosmetics launch or managing an existing portfolio on the CPNP. It explains what the portal requires, where submissions commonly go wrong, and how to manage a multi-product portfolio efficiently.

What Is the CPNP?

The Cosmetic Products Notification Portal is an online platform operated by the European Commission. It serves two primary functions: it fulfils the pre-market notification requirement under Article 13 of the Cosmetics Regulation, and it provides poison centres and emergency medical personnel across the EU with access to product composition data for toxicological response purposes.

Access to the CPNP is restricted to Responsible Persons and their authorised representatives. A brand that is not established in the EU cannot submit directly — notifications must be submitted by or on behalf of the EU-established Responsible Person.

The CPNP is separate from national notification systems that some member states operated under the previous Cosmetics Directive. Since the Cosmetics Regulation became applicable in 2013, the CPNP has been the single notification point for the entire EU market.

What Information Is Required for a CPNP Notification?

Article 13(1) of the Regulation specifies the information that must be submitted at the time of notification:

Product category and name. The product must be assigned to one of the CPNP’s predefined categories (e.g., skin care, hair care, oral hygiene, decorative cosmetics). The product name as it appears on the label must be entered.

Country of first placement on the market. The notification must specify the EU member state where the product will first be placed on the market.

Responsible Person details. The name and address of the Responsible Person must be confirmed. If the notification is submitted by a distributor on behalf of the RP, this must be documented.

Presence of nanomaterials. If the product contains nanomaterials, specific additional information is required under Article 13(1)(d), including the name of the nanomaterials and their reasonably foreseeable exposure conditions.

Frame formulation or full ingredient list. The CPNP accepts either a frame formulation (a reference to a pre-registered formulation template) or a full ingredient list with concentration ranges. For poison centre purposes, the system requires sufficient compositional detail to allow toxicological assessment.

Original label and translation. A copy of the label as it appears on the product must be uploaded. If the label is not in English, a translation may be required for certain fields.

CMR substances. If the product contains substances classified as CMR category 1A or 1B that are permitted under the exceptions in Article 15, this must be declared.

Common Submission Errors

Incorrect product category selection. The CPNP’s category taxonomy is specific. A product that functions as both a moisturiser and a sunscreen, for example, needs to be assigned to the correct primary category. Miscategorisation can affect how the notification is processed and how poison centre data is organised.

Incomplete or inaccurate ingredient information. The CPNP requires INCI names for all ingredients. Trade names, internal codes, or non-INCI nomenclature are not accepted. Brands sourcing ingredients from non-EU suppliers sometimes receive ingredient lists using non-INCI terminology, which must be converted before submission.

Concentration ranges that are too broad. For poison centre purposes, the CPNP requires concentration information within defined ranges. Submitting all ingredients at “trace” or providing only qualitative information without concentration ranges is not compliant.

Failure to update notifications after reformulation. Article 13(3) of the Regulation requires that the Responsible Person update the CPNP notification when there is a change in the information submitted. A reformulation — even a minor one — that changes the ingredient list or concentration ranges requires an updated notification. This is an ongoing obligation that brands sometimes overlook after the initial launch.

Nanomaterial declarations. Brands that include ingredients containing nanomaterials — certain titanium dioxide or zinc oxide sunscreen grades, for example — must ensure that the nanomaterial declaration is complete. The definition of a nanomaterial under the Cosmetics Regulation has specific technical parameters that should be verified with the ingredient supplier.

Managing a Multi-Product Portfolio

For brands with large portfolios, CPNP management can become a significant administrative burden. Several practices help manage this efficiently:

Maintain a notification register. A centralised register that tracks each product’s CPNP notification reference number, submission date, current status, and any pending updates is essential. This register should be reviewed whenever a formulation change, label update, or new market launch is planned.

Use frame formulations where possible. The CPNP allows the use of frame formulations — pre-registered composition templates — which can simplify notifications for products that share a common base formulation. This is particularly useful for brands with product lines that vary only in fragrance or colorant.

Assign clear ownership of the update obligation. The obligation to update the CPNP after a change is easy to miss in organisations where formulation decisions and regulatory compliance are handled by different teams. A clear internal protocol — requiring regulatory sign-off before any formulation or label change is finalised — helps prevent compliance gaps.

Practical Action Step

Use this checklist before submitting a CPNP notification:

Confirm the Responsible Person has an active CPNP account
Assign the product to the correct CPNP category
Prepare a full INCI ingredient list with concentration ranges in the CPNP-required format
Identify any nanomaterials and prepare the required nanomaterial declaration
Upload the current label (and translation if required)
Confirm the country of first placement on the market
Record the CPNP notification reference number in your compliance register
Establish an internal protocol for updating the notification after any formulation or label change

The CPNP is a technical system with specific data requirements. Errors in the initial submission are correctable, but they create administrative work and, in some cases, compliance gaps during the correction period. Consult a qualified EU regulatory expert if you are managing your first CPNP submission or migrating a large portfolio.

Care Europe manages CPNP notifications for cosmetic brands entering and operating in the EU market, including portfolio management and update protocols. Contact us to discuss your notification requirements.

The CPNP Portal — How to Notify a Cosmetic Product in the EU