CPNP Notification: Step-by-Step Guide + Common Mistakes That Cost Time and Money
Anyone bringing a cosmetic product to market in the EU must notify it in the Cosmetic Products Notification Portal (CPNP) before it is placed on the market. Without a valid CPNP notification, your product may not be sold — neither online nor in physical retail.
In this guide you will learn what the CPNP notification is, who may submit it, which details are required, and which common mistakes can cost you time and money. With the step-by-step instructions and the checklist at the end, you will be optimally prepared.
What is a CPNP notification?
The Cosmetic Products Notification Portal (CPNP) is the European Commission’s central online portal for the notification of cosmetic products. It was introduced to give the authorities of the EU Member States a consistent overview of all cosmetic products on the market.
Legal basis
Art. 13 of Regulation (EC) No 1223/2009 requires the Responsible Person to submit certain product information to the Commission electronically before it is placed on the market.
Before a cosmetic product is made available in the EU, the Responsible Person must submit the following information electronically: product category, trade name, country of origin, Member State of first making available, contact details, formulation and labelling.
The CPNP notification does not replace a safety assessment (CPSR). It presupposes that your Product Information File (PIF) is complete. First the PIF, then the CPNP — not the other way around.
Who may submit a CPNP notification?
Only the Responsible Person (as defined in Art. 4 of EU Regulation 1223/2009) or an authorised representative may submit the notification in the CPNP. This applies to three groups:
Manufacturer established in the EU
Produces and sells under its own name within the EU.
Importer
Brings products from non-EU countries into the EU market and assumes responsibility.
Authorised representative
Designated in writing by a non-EU manufacturer to act as the RP.
Remember
The Responsible Person is personally liable if something goes wrong. Whoever is registered in the CPNP as the Responsible Person bears the full regulatory responsibility for the product — including recall and damages.
CPNP notification step by step — a practical guide
The following guide takes you through all nine steps of a CPNP notification. Prepare all your documents before you open the portal — this saves rework.
Step 1: Create an account in EU Login
Access to the CPNP is via the central EU Login system of the European Commission. You need a business email address and valid company details. Registration and sign-in take place directly through the official CPNP portal. Without verified company information, access is not possible.
Step 2: Register the Responsible Person
In the next step you register the Responsible Person with the following mandatory details:
- Company name (exactly as on the label)
- Full business address
- Contact person with first and last name
- Telephone number
- Email address
These details must match the label and the PIF exactly. Discrepancies lead to objections from market surveillance.
Step 3: Select the product category
You must define the correct product category in the portal. The category determines which exposure assessment is applied in the safety assessment. Typical categories:
Skin care
Creams, lotions, serums, body oil
Hair care
Shampoo, conditioner, hair oils
Decorative cosmetics
Make-up, lipstick, nail polish
Sun protection
Sunscreen, after-sun products
Wrong category = wrong exposure assessment. This can mean that the entire safety assessment has to be revised.
Step 4: Product identification
The following information is required for product identification:
- Trade name of the product
- Product type (leave-on, rinse-off, etc.)
- Member State of first making available
- Packaging type (tube, jar, bottle, dispenser)
Step 5: Upload the formulation
The formulation is the core of the CPNP notification. The portal requires a complete quantitative composition:
- All ingredients with their INCI names
- Exact concentrations as percentages
- CAS numbers (required for regulated substances)
- Correct declaration of fragrance allergens
Caution — the most common source of errors
The formulation format must be exactly right. This is where most mistakes occur: incorrect percentages, inconsistent INCI names or missing fragrance allergens. Check the formulation three times before you upload it.
Step 6: Upload the labelling (label)
The CPNP requires a photo or PDF of your label. The following elements must be fully legible:
- Complete INCI list
- All mandatory warnings
- Minimum durability information (PAO or best-before date)
- Batch code (or placeholder)
- Name and address of the Responsible Person
Label and formulation must be identical. The INCI list on the label must contain exactly the same ingredients in the same order as the formulation stored in the portal.
Step 7: Nanomaterials (if applicable)
If your product contains nanomaterials (e.g. nano titanium dioxide or nano zinc oxide in sun protection products), a separate notification is required. This must be made six months before it is placed on the market (Art. 16 of EU Regulation 1223/2009).
Step 8: Data relevant to poison centres
The formulation stored in the CPNP is made available to the national poison centres. In the event of poisoning, doctors can quickly retrieve the relevant ingredients and their concentrations. This data is critical for emergency treatment.
Step 9: Submit the notification
After submitting, you receive a reference number. This number serves as proof of notification and should be archived together with the PIF.
Important
The CPNP notification does not confirm your product’s conformity. It is a notification, not an authorisation. Responsibility for product safety remains with the Responsible Person.
CPNP required information — checklist
Prepare all of the following documents before you start the CPNP notification. Missing documents lead to interruptions and rework:
CPNP notification — preparation checklist
- Complete formulation (quantitative, with INCI and concentrations)
- Safety assessment (CPSR) completed and signed
- Product Information File (PIF) fully compiled
- Product category correctly defined and documented
- Label finalised and available as a high-resolution file
- Responsible Person correctly named (identical to the label)
- Label images of good quality (legible, complete, not cut off)
Common CPNP notification mistakes
The following mistakes cost time and regularly lead to queries from authorities or trade partners. Avoid them by systematically checking your documents before the notification.
Inconsistent INCI names
The formulation contains "Aqua", but the label shows "Water". Neither is wrong, but combined they are inconsistent. INCI nomenclature must be used consistently.
Label does not match the formulation
The formulation has been changed, but the uploaded label still corresponds to the old version. Every formulation change requires an updated label.
Incorrect formulation format
Percentages are missing or incorrectly formatted. Concentrations given as ranges instead of exact values. Fragrance allergens not declared individually.
Missing or illegible label images
Cropped photos, resolution too low or a missing back label. The entire label must be complete and legible.
Wrong Responsible Person
The importer is not correctly registered as the Responsible Person, or the address differs from the label.
Variants not cleanly separated
Different colours or fragrances need separate notifications if the composition differs. Only identical formulations can be grouped together as shades.
Why structured data is crucial
Most problems with the CPNP notification arise not in the portal itself but beforehand. Typical causes:
- Excel versions of the formulation do not match
- The formulation file is outdated or has been overwritten manually
- The label has not been synchronised with the current formulation
- The safety assessment (CPSR) is based on an old formulation version
- Raw material data (INCI, CAS) differs across different documents
Without clean version control and central data management, the CPNP notification becomes a source of errors. Every inconsistency between formulation, label and PIF costs time — and, in the worst case, delays market entry by weeks.
Note: prepare CPNP data with INCIkit
INCIkit manages formulations with version control, including an INCI database, automatic declaration and batch traceability. All CPNP-relevant data — formulation, INCI list, product category and labelling information — is therefore held consistently and up to date in one place. This eliminates the most common sources of error before the notification.
Manage formulations centrally — CPNP-ready
INCIkit manages your formulations with version control, including an INCI database, concentrations and batch traceability — so that the CPNP notification is right first time.
CPNP pre-launch checklist
Check these points immediately before launch. If even one point is not cleanly completed, the notification becomes error-prone:
Pre-launch check before the CPNP notification
- Formulation finally versioned (no open changes)
- Safety assessment (CPSR) updated on the basis of the final formulation
- Label checked for content and appearance (INCI order, warnings, RP address)
- Responsible Person correct and identical in PIF, label and CPNP
- Product category validated (consistent with the CPSR exposure assessment)
- Batch code defined (format established)
Conclusion
The CPNP notification itself is technically straightforward — the portal guides you through the individual steps. The real challenge lies in the preparation: those who manage formulation, PIF and label in a structured way and document version histories cleanly will notify faster and without errors.
The three most important success factors:
Central data management
Maintain formulation, label and PIF in one place, not in scattered Excel files.
Version control
Document every formulation change and synchronise all dependent documents.
Consistency check before the notification
Systematically reconcile formulation, label and CPSR before you open the portal.
Unstructured documentation costs weeks. Those who have their data under control are done in minutes.
FAQ — frequently asked questions about the CPNP notification
Is the CPNP notification subject to a fee?
No. Use of the Cosmetic Products Notification Portal (CPNP) is free of charge. The European Commission provides the portal to all Responsible Persons in the EU without any fees. Costs may arise from compiling the PIF, from the safety assessment (CPSR) or from engaging a regulatory service provider.
Do I need a separate CPNP notification for each colour variant?
That depends on the composition. Variants with an identical formulation (e.g. only different packaging) can be recorded as shades under a single notification. However, if the composition differs (different pigments, different fragrances), a separate notification is required. Check the formulation of each variant carefully.
What happens if I sell my product without a CPNP notification?
Placing a product on the market without a CPNP notification breaches Art. 13 of the EU Cosmetics Regulation (EC) No 1223/2009. The market surveillance authority can impose a sales ban, order a recall and levy fines. In addition, the Responsible Person is personally liable.
Can I amend the CPNP notification afterwards?
Yes. The Responsible Person can update existing notifications in the CPNP at any time, for example following formulation changes, new brand names or a change of Responsible Person. The update must be made before the amended version is placed on the market.
Do I also need a CPNP notification for professional cosmetics (hair salons)?
Yes. The CPNP notification obligation applies to all cosmetic products made available in the EU, regardless of whether they are sold to end consumers or professional users. There is no exemption for professional-use products.
Further reading
CPNP notification — overview & software
A compact overview: the data you need, common mistakes and how INCIkit simplifies CPNP preparation.
Creating a PIF — a practical guide
The Product Information File is a prerequisite for the CPNP notification — here is how to create it correctly.
GMP & ISO 22716 guide
GMP-compliant manufacturing is part of the CPNP requirements — batch records, SOPs and quality control.
Want to document your cosmetics with full compliance?
INCIkit builds PIF, INCI list and batch records from your formula data — ready for the authority check.
INCIkit Editorial
Cosmetics Compliance Desk
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