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CPNP notification: how to notify a cosmetic product in the EU

The CPNP is the EU's free portal for notifying cosmetics before launch. Learn who must file, what to prepare, and how SCPN and AMMPS differ.
By Mohamed El Hjouji, founder of Carmel Cosmetics Labs ·
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Une spécialiste des affaires réglementaires compare un tube de crème au dossier technique avant la notification CPNP
Contents

    The CPNP notification (Cosmetic Products Notification Portal) is the European Commission’s free online portal where every cosmetic product must be notified before it is placed on the EU market (Article 13 of Regulation 1223/2009). The notification is made by the Responsible Person, the EU-based operator who answers for the product’s compliance.

    The key points at a glance

    • CPNP notification is mandatory, and a single notification covers the whole EU.
    • It is made by the Responsible Person established in the EU: for a product made outside the EU, that is the importer, or the person the importer mandates in writing (Article 4).
    • The portal asks for the category, frame formulation, nanomaterials, CMR substances (carcinogenic, mutagenic or toxic for reproduction) of category 1A or 1B, original labeling and a photo of the packaging.
    • Notifying is not an approval: the product must already be compliant and its PIF ready.
    • Great Britain uses the SCPN, and Morocco uses AMMPS registration.

    What is the CPNP and what is it for?

    According to the Commission’s official page, the CPNP is a “free of charge” system: once a product is notified, no further notification is needed at national level in the EU.

    This data is available to the competent authorities (market surveillance) and to poison control centers (medical treatment). A notification is a declaration, not an authorization: the CPNP user manual reminds users that a notified product is not, for that reason alone, compliant with the Regulation.

    Who must make the CPNP notification?

    CPNP notification is the duty of the Responsible Person and, in one case, of the distributor. Article 4 of Regulation 1223/2009 sets the rule: a cosmetic product may only be placed on the market if a natural or legal person is designated “within the Community” as the Responsible Person.

    The Responsible Person: the key role

    The cosmetic Responsible Person is the EU-based operator who guarantees, for every product placed on the market, compliance with the Regulation: safety, PIF, labeling, notification and cosmetovigilance. Their name and address appear on the label (Article 19).

    • EU-based manufacturer: the Responsible Person by default (except for a product that is exported and then re-imported).
    • Importer: for a product imported from a third country, each importer is the Responsible Person for the product it places on the market.
    • Authorized representative: the manufacturer or importer can designate, by written mandate, an EU-based person who accepts in writing.
    • Distributor: becomes the Responsible Person if it sells the product under its own name or brand, or if it modifies the product.

    Special case (Article 13(3)): a distributor that resells in another Member State a product already marketed in the EU, and that translates the labeling itself, makes its own declaration in the portal.

    What if your brand or your manufacturer is outside the EU?

    A brand based in Morocco or the United Kingdom cannot notify on its own. For a product made outside the EU, the Responsible Person is the EU-based importer, or the person the importer mandates in writing (Article 4, paragraph 5). The brand therefore goes through an EU-based importer or service provider. The non-EU manufacturer supplies the manufacturing information, but does not replace this Responsible Person.

    When to notify: before or after placing on the market?

    CPNP notification is made before the product is placed on the market (Article 13(1)). At launch, Article 13(2) adds the original labeling and, where legible, a photo of the packaging.

    For products containing nanomaterials, Article 16 also requires a specific notification “six months prior to being placed on the market”. This notification does not apply to nanomaterials used as regulated colorants, UV filters or preservatives (Article 16, paragraph 2), nor to products containing nanomaterials that comply with Annex III (Article 16, paragraph 3). It includes, among other things, the particle size, the estimated annual quantity, the toxicological profile and the safety data.

    One to watch: the “chemicals omnibus” package (procedure 2025/0531(COD)) was adopted at first reading by the European Parliament on October 22, 2026, after a provisional agreement in June. Its final adoption and publication in the Official Journal remain to be confirmed, as does its effect on nanomaterials in cosmetics. Until the text is published and applicable, Article 16 of Regulation 1223/2009 (notification six months before placing on the market) continues to apply.

    After that, any information that changes must be updated “without delay” (Article 13(7)).

    What information does the CPNP portal ask for?

    The cosmetic CPNP portal asks, product by product, for the information listed in Article 13 of Regulation 1223/2009. The table below follows the order of Article 13, paragraphs 1 and 2, of the consolidated text published on EUR-Lex.

    Information requestedWhat to prepareBasis
    Category and product name(s)Trade name in each Member State, category and physical formArt. 13(1) a
    Responsible PersonName and address where the PIF is kept available, identical to the labelArt. 13(1) b
    Country of originMandatory for an imported product (for example: Morocco)Art. 13(1) c
    Member State of first placing on the marketLaunch country in the EUArt. 13(1) d
    ContactA reachable natural person, with international dialing codeArt. 13(1) e
    NanomaterialsIdentification by IUPAC chemical name (international nomenclature of the International Union of Pure and Applied Chemistry) and reasonably foreseeable exposure conditionsArt. 13(1) f
    CMR substances (carcinogenic, mutagenic or toxic for reproduction) of category 1A or 1BName and CAS or EC numberArt. 13(1) g
    Frame formulation or compositionPredefined frame formulation, exact concentrations or concentration rangesArt. 13(1) h
    Labeling and packagingOriginal labeling and a legible photo of the packagingArt. 13(2)

    The frame formulation gives the category or function of the ingredients and their maximum concentration. The CPNP predefined formulation can only be used if the whole composition falls within its ranges; otherwise, you declare exact concentrations or ranges. The portal also asks whether the product is intended for children under 3 years old.

    The frame formulation is passed to poison control centers so that medical treatment can be given quickly in case of poisoning; market surveillance authorities do not have access to it (Article 13, paragraphs 5 and 6).

    The notification, the PIF and the label must match

    The cosmetic PIF (Product Information File) is the technical file that the Responsible Person keeps available for the authorities: product description, safety report, manufacturing method with a statement of compliance with good manufacturing practice (ISO 22716), and evidence of the claimed effects (Article 11). It is kept for ten years after the last batch is placed on the market. The label must carry the same Responsible Person address: review the mandatory elements of cosmetic labeling.

    How to notify a cosmetic product on the CPNP: the steps

    1. Check the product’s compliance: substances (Annexes II to VI), the product safety report prepared by a qualified assessor (Article 10), and manufacturing under good manufacturing practice and the requirements of the ISO 22716 standard.
    2. Build the PIF (Product Information File) and keep it at the Responsible Person’s address.
    3. Create an EU Login account (the European Commission’s authentication system), then request CPNP access for your organization: the first person to register becomes the local administrator.
    4. Open the CPNP portal and choose “Notify a product” (product with one or several components).
    5. Fill in the tabs: general information, Responsible Person and contact, category and frame formulation, nanomaterials and CMR.
    6. Upload the original labeling and the packaging photo when the product is placed on the market.
    7. Validate (“Notify”), keep the reference you are given, then keep the notification up to date whenever something changes.

    After launch, the Responsible Person also handles reporting of serious undesirable effects (cosmetovigilance).

    How much does a CPNP notification cost?

    Nothing on the portal side: the Commission presents the CPNP as a system that is “free of charge”. The real cost lies elsewhere: the safety report, testing, building the PIF, and the fee of the Responsible Person if you appoint one. Get these items quoted before you set your selling price.

    CPNP, SCPN, AMMPS: what are the differences between the EU, the UK and Morocco?

    Each market has its own system: selling in Paris, London and Casablanca takes three separate procedures. The table below compares the three systems based on Regulation 1223/2009, the official UK government guidance and our AMMPS guide.

    CriterionCPNP (European Union)SCPN (Great Britain)AMMPS (Morocco)
    NatureOnline notificationOnline notificationRegistration with certificate
    Legal basisRegulation (EC) 1223/2009, Art. 13Regulation 1223/2009 as retained in UK lawCircular 771 D/DMP/18 (2023) and AMMPS texts
    Who filesResponsible Person established in the EUResponsible Person established in the UKMoroccan-law company holding the certificate
    WhenBefore placing on the marketBefore placing on the market in Great BritainBefore marketing in Morocco
    PortalCPNP (European Commission)Submit cosmetic product notifications (OPSS)TARKHISS
    Filing costFreeNot specified on the official pageSee our AMMPS guide

    Outside Europe, other rules apply: see how to export to the United States or what SFDA registration for the Emirates requires.

    The SCPN has replaced the CPNP for Great Britain (England, Scotland, Wales) since Brexit. According to the OPSS, it held 861,686 notifications as of May 28, 2026, filed by 24,112 registered Responsible Persons. Northern Ireland remains attached to the CPNP, through a Responsible Person based in Northern Ireland or in the European Economic Area. The official SCPN guidance requires a Responsible Person established in the United Kingdom, separate from the EU Responsible Person.

    For Morocco, the full procedure (establishment declaration, Poison Control Center file, filing on TARKHISS) is described in our guide to AMMPS registration of a cosmetic product.

    Manufacturing in Morocco and selling in the EU: who does what?

    A brand that manufactures in Morocco and sells in Europe separates two roles: the manufacturer produces, and the EU-based Responsible Person notifies and answers to the authorities. The country of origin (Morocco) appears in the notification.

    • Manufacturer side: manufacturing under good manufacturing practice (ISO 22716 standard) and passing on the manufacturing information the PIF needs.
    • EU Responsible Person side (importer or authorized representative): up-to-date safety report, PIF held on file, notification, cosmetovigilance.
    • Brand side: choice of the Responsible Person, written contract, final labeling, claims.

    Other export formalities are detailed in our article on exporting cosmetics from Morocco to Europe, and the evolution of the European framework in our overview of European cosmetic regulations in 2026.

    Common mistakes in a CPNP notification

    Most notification errors come from a mismatch between the notification, the label and the PIF.

    • Notifying too early a formula that is still changing: every change requires updating the notification.
    • A different Responsible Person address on the label, the PIF and the notification.
    • Using a predefined frame formulation when an ingredient falls outside its ranges.
    • Forgetting shades with a different composition, which must be notified separately.
    • Ignoring the nanomaterials notification of Article 16, which comes on top of the standard notification.

    The manufacturer’s point of view

    At Carmel Cosmetics Labs, an ISO 22716 and ISO 9001 certified laboratory that has supported more than 500 brands in more than 35 countries, we see notification as the last step of a file: it is easy to complete once the formula, the safety data and the label are stable.

    Let us be clear about roles: Carmel is not a Responsible Person, neither in the EU nor in the UK, and does not notify your products for you. Our role as manufacturer is to give your Responsible Person the manufacturing information they need to build the PIF, as part of our production under ISO 22716. Our practical advice:

    • Appoint your EU Responsible Person as soon as you choose your markets, not when the products arrive.
    • Have this Responsible Person validate the label artwork before printing: their address must appear on it.
    • Freeze the formula before starting the notification, and document any later change.

    To structure this file, see our regulatory support and PIF preparation service.

    Frequently asked questions

    Do you need to notify a cosmetic product in every EU country?

    No, a single CPNP notification is enough for all Member States. The labeling, however, must be written in the language required by each country of sale: plan for several versions or a multilingual label from the packaging design stage.

    Can a Moroccan manufacturer notify directly on the CPNP?

    No, a manufacturer established in Morocco does not have access to notification as such. The European operator that places the product on the market, an importer or authorized representative, notifies and takes on the responsibility, based on the information the manufacturer provides.

    Is a product notified on the CPNP approved by the European Union?

    No. The CPNP records information, it does not issue any authorization or label. The authorities can inspect the product, request the PIF and penalize non-compliance even after a validated notification. Writing “approved by the EU” on packaging would be misleading.

    Can a CPNP notification be modified or deleted?

    A validated notification can no longer be deleted, but it must be updated without delay whenever information changes: formula, contact, address or labeling. For certain sensitive ingredients, the CPNP manual sets variation thresholds beyond which an update is mandatory.

    Is a CPNP notification valid in the United Kingdom?

    Not for Great Britain, which has had its own portal since January 1, 2021: a second notification by a British Responsible Person is required. Their address must also appear on the label of products sold there.

    Conclusion: prepare the file before you notify

    The CPNP is a free formality, but it commits the Responsible Person to data that must match the PIF and the label. If you are launching your cosmetics brand, appoint this Responsible Person early, stabilize the formula, then notify before launch, without forgetting the SCPN for Great Britain and AMMPS for Morocco.

    Want to have your range manufactured under ISO 22716 and pass on to your Responsible Person the manufacturing information they need? Book a free consultation or write to us on WhatsApp to schedule a meeting with our team.

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    Mohamed El HjoujiFounder of Carmel Cosmetics Labs

    Mohamed El Hjouji is the founder of Carmel Cosmetics Labs, a cosmetics laboratory in Agadir, Morocco, certified ISO 22716 (GMP) and ISO 9001. Specializing in white label and private label manufacturing, he supports 500+ beauty brands in over 35 countries, from formulation to production that meets EU regulations (EC No 1223/2009), registered with the FDA (MoCRA) for the US.

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