What is CPNP?
The EU notification portal, and how it differs from the Product Information File.
CPNP is the Cosmetic Products Notification Portal, the European Commission's electronic system through which a cosmetic product is notified before being placed on the EU market. It records who bears responsibility for the product and the composition details that competent authorities and poison centres may need. A CPNP notification confers no authorisation, and it does not substitute for the Product Information File (PIF), which holds the evidence on which the product's safety rests.
What CPNP is and who uses it
CPNP gives effect to Article 13 of Regulation (EC) No 1223/2009. Before a cosmetic product is placed on the EU market, the Responsible Person must submit the prescribed information electronically through the portal. Under Article 13(3), a distributor who makes a product available in a Member State and translates any element of its labelling has a notification obligation of its own.
Three points on how the system operates:
- One notification covers the entire Union.There is no Member State–by–Member State filing.
- The portal is free to use.It is operated by the European Commission and accessed through an EU Login account.
- It is not a public database.Access is granted to competent authorities for market surveillance and to poison centres under Article 13(6) for the purposes of prompt and appropriate medical treatment.
Notification is emphatically not authorisation. No authority evaluates the formulation on submission. The determination of safety remains with the Responsible Person and rests on the safety assessment held in the PIF.
What is submitted in a notification
A notification is a short record, not a dossier. Article 13(1) requires:
- the category of the cosmetic product and its name, permitting specific identification
- the name and address of the Responsible Person, being the address at which the PIF is made readily accessible
- the country of origin, in the case of import
- the Member State in which the product is to be placed on the market
- the contact details of a physical person to contact in case of necessity
- the presence of substances in the form of nanomaterials, with their identification including the chemical name (IUPAC) and other descriptors, and the reasonably foreseeable exposure conditions
- the name and CAS or EC number of substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) of category 1A or 1B under Part 3 of Annex VI to Regulation (EC) No 1272/2008
- the frame formulation, giving a poison centre sufficient information on composition to provide prompt and appropriate medical treatment
Note what is absent: no safety assessment, no test reports, no manufacturing records. That evidence belongs in the PIF and is produced to the competent authority on request.
Two obligations that are easily missed sit alongside the Article 13 filing. Products containing nanomaterials not covered by Annex III, IV, V or VI require a separate notification to the Commission under Article 16, six months prior to being placed on the market. And Article 13(7) requires the notified information to be updated whenever any of it changes.
CPNP vs PIF
The notification is the registration record; the PIF is the technical file standing behind it. The two are routinely confused because both attach to the same Responsible Person and the same product.
| Question | CPNP notification | PIF |
|---|---|---|
| What is it? | A short electronic record of the product | The complete dossier demonstrating the product is safe |
| Who is accountable? | The Responsible Person | The Responsible Person |
| Where does it reside? | In the European Commission's portal | At the address of the Responsible Person indicated on the label |
| Who has access? | Competent authorities and poison centres | Competent authorities, on request |
| What does it contain? | Identification, contacts, nanomaterials, CMRs and frame formulation | Product description, CPSR, manufacturing method and GMP statement, claim substantiation, animal-testing data |
| When is it required? | Before the product is placed on the market | Before it is placed on the market, and retained for ten years after the last batch |
| Does it establish safety? | No | Yes — that is its function |
How the two work together
The sequence matters, because the notification declares an address at which a file must already be available.
- Compile the PIF,including a CPSR whose Part B has been carried out and signed by an assessor meeting the qualification requirements of Article 10(2).
- Notify the productthrough CPNP under the Responsible Person's account.
- Place the product on the market.
- Maintain both:update the notification under Article 13(7) when the notified particulars change, and update the PIF whenever anything bearing on safety or compliance changes.
Other jurisdictions operate their own systems. The UK runs the Submit Cosmetic Product Notification service (SCPN), so a product marketed in both territories is notified twice. The US has no equivalent portal; the nearest counterpart is the product listing filed with the FDA under MoCRA. Asia-Pacific requirements vary by country, including positive-list and pre-approval regimes, and are assessed individually.
Common findings
- Treating notification as clearance.No formulation review takes place on submission. Presence in CPNP is evidence of nothing beyond the fact that a filing was made.
- Notifying before the PIF exists.The notification declares the address at which the PIF is to be made readily accessible. If an inspector attends that address, the file must be there.
- Allowing the record to drift.A change of Responsible Person, contact person, importing arrangement, nanomaterial status or frame formulation triggers the Article 13(7) update duty.
- Overlooking Article 16.A nanomaterial not covered by Annexes III to VI requires a separate notification six months in advance, independent of the Article 13 filing.
- Assuming one portal serves every market.CPNP covers the EU only. The UK, the US and other territories impose their own requirements.
- Delegating without oversight.A distributor or agency may operate the account, but the Responsible Person remains accountable for the accuracy of what is notified.
Frequently asked questions
- Is CPNP the same as the PIF?
- No. CPNP is a short electronic notification. The PIF is the full technical and safety dossier, kept readily accessible at the address of the Responsible Person.
- Does a CPNP notification mean my product is approved?
- No. It is a notification, not an authorisation. There is no pre-market review of the formulation.
- Is CPNP free, and is it public?
- It is free to use. It is not public: access is restricted to competent authorities and, for the purposes of medical treatment, poison centres.
- Do I notify each EU Member State separately?
- No. A single notification covers the whole Union, although the Member State of first placing on the market must be indicated.
- Who submits the notification?
- The Responsible Person, and in the circumstances set out in Article 13(3), a distributor. Accountability stays with the Responsible Person.
- Does the UK use CPNP?
- No. The UK operates its own Submit Cosmetic Product Notification service (SCPN), with a UK-established Responsible Person.