CPNP notification, step by step — and when you do not need us for it

The portal is free

The Cosmetic Product Notification Portal is operated by the European Commission and it costs nothing to use. There is no filing fee. There is no per-product charge from the Commission.

We are saying that first because a good deal of the content about CPNP is written by people selling notification as a line item, and a buyer arriving from a search has usually not been told the basic commercial fact about it. If someone is charging you for a notification, they are charging you for the work of doing it and for being the person entitled to do it — not for the portal.

Who is entitled to notify

The duty sits with the responsible person. Before a cosmetic product is placed on the market, the responsible person submits the required information to the Commission electronically (Art. 13(1), Reg. (EC) 1223/2009). Art. 13(2) adds a second duty on the same person: when the product is placed on the market, the responsible person notifies the Commission of the original labelling and, where reasonably legible, a photograph of the corresponding packaging.

Art. 13(3) and Art. 13(4) put narrower, separate duties on distributors — the case where a distributor makes a product already placed in one Member State available in another and translates an element of the labelling, and the case of a product placed on the market before 11 July 2013 but no longer placed on the market as from that date, which a distributor later introduces in a Member State, where the distributor communicates to the responsible person and the responsible person submits to the Commission. So it is not accurate to say that only a responsible person can ever notify anything. It is accurate to say that the duty in Art. 13(1) and 13(2) — the notification you are thinking of, for a product being placed on the market — sits with the responsible person.

That is why the DIY route fails for a non-EU brand, and the reason is structural rather than procedural. A cosmetic may be placed on the Union market only where a responsible person is designated within the Union (Art. 4(1), Reg. (EC) 1223/2009). If you have no responsible person, there is no one who bears the Art. 13(1) duty on your behalf — and the form being simple does not help.

Which reframes the problem honestly: the blocker is not the notification. It is that somebody established in the Union has to hold the role, and the notification follows from that.

What you submit

Art. 13(1), Reg. (EC) 1223/2009 lists the information the responsible person submits before placing the product on the market:

• the category of cosmetic product and its name or names, enabling specific identification;
• the name and address of the responsible person, where the product information file is made readily accessible;
• the country of origin, in the case of an imported product;
• the Member State in which the product is to be placed on the market;
• contact details of a physical person to contact in the event of necessity;
• the presence of nanomaterials, their identification, and the reasonably foreseeable exposure conditions;
• the name and CAS or EC number of any CMR substances of category 1A or 1B;
• the frame formulation, to allow prompt and appropriate medical treatment where there is difficulty.

The original labelling, and a photograph of the corresponding packaging where reasonably legible, is submitted when the product is placed on the market (Art. 13(2), Reg. (EC) 1223/2009).

Two of these are where the real work is. The frame formulation has to be correct, because it is what a poison centre reads at three in the morning. And the labelling has to be the labelling you actually print — which means the notification cannot be finished before the artwork is.

The sequence, in order

1. Create an EU Login account. That is the Commission's single sign-on; the portal sits behind it.
2. Register the responsible person's organisation in the portal, with the address at which the product information file is kept (Art. 11(1), Art. 13(1)).
3. Have the file and the signed report finished first. The notification asks where the file is kept. If the answer is "nowhere yet", you are notifying a product you have not assessed, and the obligations in Art. 10(1) and Art. 11(1) bite before placing, not after.
4. Create the product, with a name that specifically identifies it, and its category.
5. Enter the frame formulation, the nanomaterials if any, and the CMR substances of category 1A or 1B if any.
6. Upload the labelling and the packaging photograph.
7. Name the contact person who can be reached in an emergency.
8. Submit before placing on the market — placing being a product's first making available on the Community market (Art. 2(1)(h)), and the Regulation's "Community" is read as the Union.
9. Keep the reference, and keep the notification in step with the product. If the label changes, the notification changes.

Most people's problem with CPNP is not step 4. It is that steps 1 to 3 were never done, and the portal is the place where that becomes obvious.

When you do not need us

We could not find this section on a competitor's page, so here it is plainly.

You do not need us if you are established in the EU and are your own responsible person. You can register in the portal yourself and notify your own products. It is a form. It is tedious and it is free. What you will still need from someone is the safety assessment, because that requires a person holding the qualification in Art. 10(2) — but the notification itself is genuinely yours to do.

You do not need us if your product is not a cosmetic. A candle, a reed diffuser, a room spray, a supplement, a device: not a cosmetic under Art. 2(1)(a), not notified on CPNP, different rules entirely. We would rather tell you that in the free check than sell you a notification you do not need.

You do not need us if you are a distributor of product someone else has already placed on the EU market under their own name. Their responsible person carries the Art. 13 duty. Ask them for evidence rather than building a parallel file. (If you relabel or translate, look carefully at Art. 13(3) — that is a case where a duty does attach to you.)

You do not need us if you are not placing product on the Union market at all.

You probably do need someone if you are established outside the EU. Not because notification is hard, but because Art. 4(1) means there has to be a legal or natural person designated within the Union before the product can be placed at all. For an imported product the importer is the responsible person unless it designates, by written mandate, a person established within the Union who accepts the role in writing (Art. 4(5), Reg. (EC) 1223/2009). That person is the one who notifies.

We can be appointed as your EU Responsible Person, by written mandate. How that works →

What it costs

Notification sits inside the registration band rather than being a line added to it. You are not charged separately for a portal form the Commission gives away — what is charged is the work behind it and the role that makes it possible.

What each band covers, and the price of each, is on the pricing page. You get a fixed quote in writing, against your products, before any work starts: what is included, what is not, and what counts as a variant.

FAQ