CPNP: What the Cosmetic Product Notification Portal Is and How to Notify

• The CPNP is the European Commission's free, mandatory online notification system implementing Art. 13 of Regulation (EC) 1223/2009 — a single notification covers the entire EU.
• Notification is prior to market placement, is submitted by the Responsible Person, and has replaced all national notification systems since 11 July 2013.
• Products containing nanomaterials require a separate notification six months in advance via the CPNP nanomaterial module (Art. 16(3)).

1. What is the CPNP?

The Cosmetic Products Notification Portal (CPNP) is the online notification system created by the European Commission to implement Regulation (EC) No 1223/2009. Its official description defines it as "a free of charge online notification system created for the implementation of Regulation (EC) No 1223/2009 on cosmetic products".

Three characteristics define it:

• Free of charge: there is no fee to submit or update any notification.
• Mandatory since 11 July 2013: the date Regulation 1223/2009 became fully applicable and the CPNP replaced all national notification systems across the EU.
• Single portal for the entire EU: one notification in the CPNP covers the market of all 27 Member States.

The portal is managed under the Directorate-General for Internal Market (DG GROW) and is accessible through the European Commission's webgate platform.

Who can access the CPNP and for what purpose:

2. Legal basis: Article 13 of Regulation 1223/2009

Regulation (EC) 1223/2009 governs CPNP notification in Article 13, with the following key paragraphs:

• Art. 13(1): the Responsible Person notifies before market placement the fields set out in the article (see table in section 4).
• Art. 13(2): when the product is placed on the market, the original labelling and a photograph of the packaging are added.
• Art. 13(3): a distributor who translates labelling elements on their own initiative to make an already-marketed product available in another Member State must submit their own notification, covering the product category in the originating and destination states, the distributor's details, and the Responsible Person's details.
• Art. 13(4): for products marketed before 11 July 2013 — if a distributor reintroduces them into a Member State, the Responsible Person must notify if not previously done.
• Art. 13(7): when any information notified under paragraphs 1, 3 and 4 changes, the Responsible Person or distributor must update without delay.

Article 13 is an obligation of result: notification must occur before market placement, not simultaneously or after the fact.

3. Who must notify?

The Responsible Person is the primary obligated party. Article 4 of the Regulation defines who can be a Responsible Person:

• A manufacturer established in the EU who markets products under their own name or brand.
• An authorised representative explicitly designated in writing by a non-EU manufacturer.
• An importer who places the product on the EU market.
• A distributor who markets the product under their own name or brand, or who modifies a product already on the market in a way that may affect its compliance.

The guide on Responsible Person obligations covers all four profiles and their associated obligations in detail.

The special case of the distributor (Art. 13(3)): a distributor who translates labelling on their own initiative to make a product available in another Member State takes on their own notification obligation, independent of that of the original Responsible Person.

Brands not established in the EU: they cannot notify directly. They must do so through the Responsible Person acting as authorised representative, importer, or distributor assuming responsibility within the Union.

4. What information is notified (table)

Article 13(1) sets out the fields the Responsible Person must notify before market placement. Article 13(2) adds the fields incorporated at the moment of placing on the market:

5. When to notify

The Regulation establishes three distinct timing requirements depending on the notification type:

Standard notification (Art. 13(1)): must be completed before market placement. There is no grace period: the product cannot be commercialised without prior notification.

Nanomaterials (Art. 16(3)): notification must be made six months before market placement, via the dedicated CPNP nanomaterial module. This is additional to and independent of the standard Art. 13 notification.

Updates (Art. 13(7)): when any notified data changes, the update must be made "without delay". The Regulation does not specify a fixed deadline beyond the immediacy implied by "without delay".

A summary of the sequence of actions:

1. Check whether the product contains nanomaterials → if so, notify 6 months in advance (Art. 16(3)).
2. Notify the product in the CPNP before market placement (Art. 13(1)).
3. Add the labelling and packaging photograph at the moment of market placement (Art. 13(2)).
4. Keep the notification updated whenever any notified information changes (Art. 13(7)).

6. The special case of nanomaterials (Art. 16)

Regulation 1223/2009 establishes in Article 16 a specific regime for cosmetic products containing nanomaterials, with a notification process differentiated from that of Article 13.

When Article 16 applies: when the cosmetic product contains nanomaterials as defined in Article 2(1)(k) of the Regulation. Nanomaterials that were already on the market before 11 January 2013 are excluded.

The six-month rule (Art. 16(3)): the Responsible Person must notify the product on the CPNP via the dedicated nanomaterial module six months before commercialisation. This notification includes:

• IUPAC name of the nanomaterial.
• Nanomaterial specifications (particle size, physico-chemical characteristics).
• Estimated quantity of the nanomaterial in the product.
• Toxicological profile of the nanomaterial.
• Safety data and reasonably foreseeable conditions of exposure.

Relationship with Art. 13: the Art. 16(3) notification does not replace the Art. 13 notification. They are independent obligations and both must be fulfilled. The nanomaterial module in the CPNP is a separate workflow from the standard notification module.

Consequence of missing the deadline: placing a product on the market without having notified its nanomaterials six months in advance constitutes a direct breach of the Regulation, even if the standard Art. 13 notification was completed correctly.

7. CPNP and PIF: distinct obligations

A common source of confusion in practice is treating the CPNP notification and the product information file (PIF) as equivalent or interchangeable obligations. They are not.

In the CPNP notification, the Responsible Person indicates where the PIF is located (the name and address where it is accessible), but does not submit PIF content to the portal. The PIF and the CPNP coexist as complementary obligations — neither replaces the other.

8. Common errors and how to avoid them

Practice in CPNP notification reveals five types of error with direct regulatory consequences:

1. Not updating the notification after reformulation. Article 13(7) is clear: any change in notified information requires an update without delay. Continuing to market under a notification that does not reflect the current formula is an ongoing breach.

2. The distributor translates the label without notifying. When a distributor translates any labelling element on their own initiative to make a product available in another Member State, Article 13(3) imposes their own notification obligation. Many distributors are unaware of this requirement.

3. Confusing CPNP notification with the PIF. They are independent obligations. Completing the CPNP notification does not exempt from maintaining a complete and current PIF, and vice versa.

4. Omitting the nanomaterial module. The Art. 16(3) module is a separate process with a six-month advance deadline. It is not automatically triggered by completing the standard Art. 13 notification. If the product contains nanomaterials and this module has not been completed with the required advance notice, the product cannot be placed on the market.

5. Treating notification as a one-time task. CPNP notification is a continuing obligation. Any change in any notified data triggers the obligation to update. A product correctly notified at launch may breach Art. 13(7) if the notification is not kept current.

9. Frequently asked questions

Is CPNP notification free of charge? Yes. CPNP notification is free of charge, as confirmed by the official European Commission page. There is no fee to submit or update a notification.

Does CPNP notification replace national notifications? Yes. Since 11 July 2013, a single CPNP notification covers the entire EU market. It replaced all pre-existing national notification systems across all Member States. No additional notifications are required at the national level.

What happens when the formula or any notified information changes? Article 13(7) of Regulation 1223/2009 requires the Responsible Person or distributor to update the notification "without delay" when any information notified under paragraphs 1, 3 and 4 changes. Continuing to market a reformulated product under the original notification is a direct compliance breach.

Can a manufacturer outside the EU notify directly in the CPNP? No. Only the Responsible Person established in the EU can submit CPNP notifications. Manufacturers based outside the EU must act through their authorised representative, importer, or the person who assumes the Responsible Person role within the Union.

What is a frame formulation in the CPNP? A frame formulation is a standard composition option provided for medical treatment and poison centre purposes. When a formula falls within standard concentration ranges, the notifier can indicate the corresponding frame formulation instead of declaring the full composition. It allows omitting exact concentrations of lower-risk specific ingredients.

When must nanomaterials be notified in the CPNP? Cosmetic products containing nanomaterials must be notified separately via the dedicated CPNP nanomaterial module six months before being placed on the market, pursuant to Article 16(3) of Regulation 1223/2009. This notification is independent of and additional to the standard Article 13 notification.