To enter the EU market, cosmetics must be notified in the CPNP before they are placed on the market. In this issue, EVERBIZ covers four things: what it is, who notifies, how to notify and what to prepare.
What Is the CPNP?
The CPNP (Cosmetic Products Notification Portal) is the EU’s online notification system for cosmetics, under Article 13 of the EU Cosmetics Regulation (EC) No 1223/2009.
Free to use; one notification is valid in all EU Member States;
The information is not public; it is used by competent authorities for market surveillance and by poison centers for emergency response, e.g. checking the formula in case of accidental ingestion.
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Who Notifies?
The EU Responsible Person (RP) is responsible for notification and must be established in the EU;
Brands outside the EU cannot act as RP themselves; the role must be taken by the importer or an EU entity designated in writing;
Distributors that bring a product into another Member State and translate the label themselves must also submit a distributor notification.
EVERBIZ has offices in Munich, Germany and Salzburg, Austria, and can act as EU Responsible Person (RP) for companies.
Notification Process
1. Appoint an EU Responsible Person
2. Prepare documents: PIF, CPSR safety assessment, labeling and packaging
3. Register a system account and set access rights
4. Submit the notification online
5. Post-market maintenance: update the information promptly when it changes
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Regulatory reminder: the number hasn’t changed, but the content keeps being updated
EVERBIZ tip: the basic regulation is still (EC) No 1223/2009, but the annexes listing prohibited and restricted substances, preservatives, UV filters, etc. are continually updated by amending regulations. Always check against the latest consolidated version – not just the 2009 original.
What Information Must Be Notified?
Product category and name (matching the actual packaging)
Name and address of the Responsible Person (including where the PIF is kept)
Country of origin for imported products
EU Member State where the product is first placed on the market
Emergency contact details
Information on nanomaterials (if any)
Name and CAS or EC number of Category 1A/1B CMR substances (if any)
Frame formulation information for medical treatment
Photos of the original labeling and packaging (to be submitted at the latest when the product is placed on the market)
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Core documents: PIF and CPSR
PIF – Product Information File
Includes a product description, the CPSR safety report, the manufacturing method and GMP statement, proof of claimed effects and relevant animal testing data.
Supporting documents such as factory information, ISO 22716 certificate (if any) and batch production and release records should also be ready.
The PIF must be kept for 10 years from the date the last batch was placed on the market.
CPSR – Cosmetic Product Safety Report
A mandatory pre-market document assessing whether the product is safe under normal and reasonably foreseeable conditions of use, in two parts:
Part A – Safety information: data on ingredients, stability, use, etc.;
Part B – Safety assessment: the conclusion of a qualified safety assessor, with any necessary warnings and instructions for use.
EVERBIZ recommends: complete the CPSR first, then submit the notification, to make sure the formula, labeling and notification information are consistent.
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Next time, we’ll look at how to prepare the PIF and CPSR and common problems when compiling the documents.
If you need help with EU cosmetic notification, a Responsible Person or document preparation, contact EVERBIZ.
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EU Responsible Person · CPNP notification · PIF / CPSR document support
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