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Before a single unit of your cosmetic product reaches an EU shelf, it has to exist somewhere else first: inside the Cosmetic Products Notification Portal (CPNP), the European Commission’s database created to implement Regulation (EC) No 1223/2009. Article 13 of the Regulation makes this notification a precondition for placing the product on the market — not a formality you can leave for later. We have seen shipments cleared at customs and then held at the distributor’s warehouse because nobody had actually completed the CPNP step; the paperwork existed, the notification did not.
Who can notify, and why it is not the manufacturer by default
Only the Responsible Person (RP) — a natural or legal person established within the EU — can submit a CPNP notification. If your company manufactures outside the Union, you cannot notify directly: you need to designate an EU-established Responsible Person, who takes on legal accountability for the product’s safety file, labelling and market surveillance response. This is frequently where non-EU brands lose time: they assume notification is an administrative step their distributor will «sort out», without realising that whoever signs as RP is the one an inspector will call first.
The three steps of a CPNP notification
The process itself is not complex once the underlying documentation is ready. First, the Responsible Person creates an EU Login account, the Commission’s shared authentication system used across CPNP and other EU portals. Second, within CPNP’s organisation module (SAAS), the RP sets up or joins an organisation profile and declares its role — Responsible Person, distributor or delegate — since CPNP allows a delegate to submit on the RP’s behalf while the legal responsibility still sits with the RP. Third, the RP notifies each product individually: category (skin care, hair care, oral hygiene, decorative cosmetics, among CPNP’s predefined categories), the product name exactly as it appears on the label, the RP’s name and address, the country of origin when manufactured outside the EU, and the member state(s) where it will first be placed on the market.
The formulation itself can be declared either as a frame formulation — a reference to a pre-registered formulation template, when one applies to your product type — or as the full ingredient list with concentration ranges. Where the formula contains a substance classified as CMR (carcinogenic, mutagenic or toxic for reproduction, category 1A or 1B under the CLP Regulation), CPNP requires its concentration and function to be declared separately, and the presence of any nanomaterial must be flagged as such. A legible copy of the original label, and ideally a product photo, complete the file.
Notified does not mean cleared
Here is the detail that catches out companies moving fast to launch: CPNP has no official review process. The notification reference is issued immediately once the form is submitted, and that reference number is not an approval — it simply confirms the product exists in the database. Responsibility for the product’s actual safety and conformity with the Regulation, including the Cosmetic Product Safety Report (CPSR) and the ingredient assessment behind it, remains entirely with the Responsible Person from day one. A market surveillance authority can request the full file at any point, notification reference notwithstanding.
The obligation does not end at launch either. Under Article 13(7) of the Regulation, the Responsible Person must update the CPNP notification whenever the information submitted changes — a reformulation that alters the ingredient list or concentration ranges, a change of manufacturing country, or discontinuation of the product all trigger an update. In our experience, this is the step companies forget most often: they treat the initial notification as a one-time task, then reformulate a product eighteen months later without touching CPNP, leaving the database out of step with what is actually being sold.
CPNP is not Spain’s own import declaration
CPNP notification is frequently confused with Spain’s national declaración responsable for cosmetics manufacturing or import activity, processed through AEMPS via the COSMET2 platform under Royal Decree 85/2018 — we cover that process in detail in our guide to importing cosmetics into Spain. The two are not alternatives: CPNP notifies the product, at EU level, before it reaches any market; the Spanish declaración responsable authorises the company’s facility and activity to manufacture or import cosmetics on Spanish territory. A company placing cosmetics on the Spanish market from outside the EU typically needs both in place, each satisfying a different legal requirement.
Frequently asked questions
Does a CPNP notification reference number mean my product is approved for sale?
No. The reference is issued automatically and only confirms the product is in the database. The Responsible Person remains fully liable for the product’s safety file and its conformity with Regulation (EC) 1223/2009.
What happens if I reformulate a product after it has been notified?
Article 13(7) requires an updated notification whenever the submitted information changes, including ingredient list or concentration ranges. Selling the reformulated product under the old notification is a non-conformity.
How ASC Services helps
We act as Responsible Person or support your own RP through the full CPNP notification — formulation review, CMR and nanomaterial flagging, frame formulation matching where it applies — alongside the CPSR that has to back it up, and we keep the notification updated whenever your formula or your markets change. If you are also entering the Spanish market specifically, we coordinate the CPNP notification with the COSMET2 declaración responsable so neither obligation is left half-done. Talk to our team before you launch, not after a market surveillance authority asks for the file you assumed was already complete.