Last reviewed: 23 September 2026 | For: brand owners, private-label businesses, importers and distributors selling finished cosmetic products in the EU.
Do cosmetics need CPNP notification before sale in Europe?
For a finished cosmetic product placed on the European Union market, notification through CPNP is generally required before it is placed on the market. Article 13 of Regulation (EC) No 1223/2009 requires the responsible person—and, in defined circumstances, a distributor—to submit specified information electronically. The European Commission describes CPNP as the EU’s free, centralised notification system; once a product has been notified, a further national notification within the EU is not required.
This is a notification system. It does not mean that the Commission has approved the product, reviewed every claim, or issued a certificate. The brand still needs a compliant product, an EU Responsible Person, safety documentation, accurate labelling and post-market controls.
| Market | Pre-market portal step | Key operator | What it is not |
|---|---|---|---|
| European Union | CPNP notification before placing the finished cosmetic product on the EU market | EU Responsible Person; certain distributors in defined cases | EU-wide product approval or a voluntary certificate |
| United Kingdom | Separate UK notification route may apply for Great Britain | UK Responsible Person where applicable | An extension of the EU CPNP notification |
What is CPNP?
The Cosmetic Products Notification Portal is an electronic system created to implement the EU Cosmetics Regulation. It makes selected product information available to competent authorities for market-surveillance purposes and to poison centres or similar bodies for medical treatment purposes. It is not a consumer-facing product directory and does not replace the PIF kept by the Responsible Person.
Who must submit the notification?
The usual notifier is the EU Responsible Person. Under Article 4 of the Regulation, only products for which a legal or natural person is designated as the Responsible Person within the EU may be placed on the EU market. A distributor may also have a notification obligation in the specific situation described in Article 13(3), for example where that distributor translates, on its own initiative, an element of the label to comply with national law.
A non-EU brand owner or OEM/ODM manufacturer can prepare information and support the submission, but that does not by itself make it the EU Responsible Person. Confirm roles contractually before notification begins.
| Requirement | Why it matters | Typical owner |
|---|---|---|
| EU Responsible Person | Provides the accountable EU contact and maintains regulatory obligations | Brand-appointed EU entity or qualified service provider |
| CPNP notification | Supplies Article 13 information to the central EU portal before market placement | Responsible Person or authorised delegate |
| PIF and CPSR | Support the product safety assessment and retained compliance evidence | Responsible Person with inputs from brand and manufacturer |
| EU-compliant artwork | Ensures mandatory label information is available on the marketed pack | Brand owner and Responsible Person, with manufacturer data support |
What information is normally notified?
Article 13 sets out the notification framework. Exact data should be checked against the current portal workflow and the product’s formulation. In practice, the Responsible Person should have a controlled product dossier ready before the submission, including the product category and name, Responsible Person details, country of origin where applicable, Member State of first placement, emergency contact details, and relevant composition information. For products containing nanomaterials, Article 16 creates an additional notification route and timing requirement.
Do not use CPNP to compensate for missing safety work. The European Commission’s legislation guidance states that manufacturers must prepare a product safety report before placing a product on the market; the Regulation also ties market placement to an EU Responsible Person.
CPNP notification, CPSR and PIF: the practical difference
- CPNP: a notification to the EU portal.
- CPSR: the cosmetic product safety report supporting the safety assessment.
- PIF: the retained product information file that includes the CPSR and other required information.
- Label: the consumer-facing pack information that must match the product and applicable EU rules.
A portal entry does not remove the need to maintain the underlying records. It also does not guarantee that a product claim, ingredient use level or packaging presentation is compliant.
Recommended sequence before EU launch
- Confirm that the product is a cosmetic product and identify the intended EU markets.
- Appoint the EU Responsible Person and agree document responsibilities.
- Complete formula, safety, manufacturing and label reviews; compile the PIF and CPSR inputs.
- Confirm the final marketed product and artwork are aligned with the dossier.
- Submit the CPNP notification before the product is placed on the EU market.
- Retain records and operate post-market monitoring, including serious undesirable-effect processes where relevant.
Common mistakes that delay a launch
- Calling CPNP “EU approval” or “EU registration certificate.”
- Not appointing a clearly accountable EU Responsible Person.
- Not reconciling the notified product with the final formula, pack and product name.
- Using a safety report or label that does not match the market version.
- Assuming an EU notification covers Great Britain.
- Forgetting the additional nanomaterial notification requirements where applicable.
What can a cosmetic manufacturer provide?
For an OEM/ODM project, the manufacturer can usually provide controlled technical inputs such as an INCI list, specification, COA and SDS where applicable, stability and microbiological information, manufacturing and batch documentation, packaging-compatibility information, and quality records. The brand owner and EU Responsible Person still need to decide how the finished product will be marketed, ensure that final artwork is compliant, and maintain the legally required EU file and notification responsibilities.
FAQ
Is CPNP notification mandatory?
For cosmetic products placed on the EU market, Article 13 sets out a pre-market CPNP notification requirement for Responsible Persons and, in certain cases, distributors. Check the current Regulation and portal guidance for the exact product and operator situation.
Does CPNP notification mean the product is approved?
No. CPNP is a notification system. It does not replace safety evidence, labelling compliance, a PIF, a CPSR or the Responsible Person’s ongoing obligations.
Can a Chinese or US brand submit CPNP itself?
A non-EU brand can support the dossier and use an authorised workflow, but an EU-based Responsible Person is required for a cosmetic product to be placed on the EU market. Confirm who is entering and maintaining the notification.
Do I need another notification in each EU country?
The European Commission states that once a product has been notified in CPNP, there is no further national notification need within the EU. National language, labelling and enforcement considerations can still matter.
When should CPNP be completed?
Complete the notification before the finished cosmetic product is placed on the EU market, after the final product information has been controlled.
Official sources
- European Commission: Cosmetic product notification portal (CPNP)
- European Commission: Cosmetics legislation
- EUR-Lex: Regulation (EC) No 1223/2009 on cosmetic products
Need manufacturing documentation support for an EU cosmetics project? MOOYAM provides cosmetic OEM/ODM manufacturing and technical documentation support for international beauty brands. Contact us to discuss your product and target market.
Regulatory requirements may change. Brands should verify current requirements with the relevant regulatory authority or qualified compliance professional before placing cosmetic products on the market.