SCPN vs CPNP: Which Cosmetic Notification Do You Need?
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Spectra Cosmetic Compliance
Notification is a distinct step from the CPSR, though it draws on the same product information. Here we focus on getting the notification right.
Cosmetic Notification Doesn't Mean Approved Here's the Difference
Notification means registering a cosmetic product on the official portal CPNP in the EU, SCPN in Great Britain before it's placed on the market. It gives authorities and, importantly, poison centres information about products on the market, so they can respond quickly if needed. Notification is a legal requirement under Regulation (EC) No 1223/2009, but it is not an approval no one reviews or signs off the product. You notify; you are not granted permission.
This distinction matters. Some brands assume notification is a green light from an authority. It isn't. Responsibility for safety and compliance stays entirely with the Responsible Person notification simply puts the authorities on record that the product exists. It's a registration, not an endorsement.
SCPN: the Great Britain system
For products placed on the Great Britain market, notification is made through the SCPN Submit Cosmetic Product Notification the portal operated by the UK's Office for Product Safety and Standards (OPSS). Since the UK left the EU, Great Britain operates this separate system, and products sold in England, Scotland and Wales must be notified here.
SCPN captures the information a UK authority and poison centre need: the product and its category, RP, the formulation framework, the presence of any substances of concern, and label information. A UK-based (or UK-established) Responsible Person is generally needed for products on the GB market.
CPNP: the EU system
For products placed on the EU market, notification is made through the CPNP the Cosmetic Products Notification Portal the European Commission's central system. A single CPNP notification covers the whole EU, so a product notified here can be sold across all member states without notifying each one separately. Northern Ireland follows the EU system under the Windsor Framework.
CPNP requires broadly similar information to SCPN, and an EU-established Responsible Person is needed for products on the EU market. The centralised nature of CPNP is a real advantage for brands selling across Europe: one notification, one portal, all member states covered.
The key difference: two separate systems
The fundamental point is that, since Brexit, SCPN and CPNP are separate and independent. There is no mutual recognition: notifying on one does not cover the other. A brand selling in both Great Britain and the EU must notify both on SCPN for GB and on CPNP for the EU and needs a Responsible Person established in each market.
This is one of the most significant practical consequences of Brexit for cosmetic brands. What was once a single notification now, for dual-market sellers, means two notifications, two RPs, and two portals to maintain. Understanding this early avoids the nasty surprise of discovering a whole market is un-notified.
What information notification requires
Both systems require broadly similar core information:
- Product name and category
- Responsible Person's details
- Frame formulation a standardised description of the product's formulation category
- Presence of any CMR substances or nanomaterials
- Label information, often including a photograph or image of the labelled product or packaging
Getting this information right is what makes a notification valid and useful. The frame formulation, and the declarations about substances of concern, must be accurate this is exactly the information a poison centre would rely on in an emergency, and it should match what's already recorded in your product information file for that product.
Who makes the notification
Notification is generally the responsibility of the Responsible Person , who must ensure the product is notified before it is placed on the market. In some circumstances a distributor making a product available in another member state, or relabelling may have notification obligations too, but the primary duty sits with the Responsible Person .
Because each market needs its own Responsible Person and its own notification, brands selling into both the UK and EU need to be clear about who holds the RP role in each, and ensure notification is completed in each system.
Timing: notify before you sell
Notification must be completed before the product is placed on the market, not afterwards. Like the CPSR, it is a pre-market step, and selling a product that has not been notified is a breach of the regulation.
Because notification draws on the finished product information including the label it usually comes near the end of the compliance sequence, after the CPSR is done and the label finalised. Planning it into your launch timeline ensures the product is fully notified before the first sale.
Notification and poison centres
One of the main purposes of notification is to give poison centres the information they need to advise in an emergency for example if a child swallows a product or someone has a serious reaction. This is why the formulation information in a notification, and the declarations about substances of concern, matter so much: they are what a medical professional might rely on when responding to an incident.
It is worth being aware that the EU also operates additional poison centre notification requirements for certain products through a separate process, over and above the CPNP cosmetic notification. Brands placing relevant products on the EU market should check whether these additional obligations apply to them, as they sit alongside, not instead of, the cosmetic notification. The precise requirements are a point to confirm for your specific products and markets.
The broader point is that notification is a safety mechanism, not merely administrative box-ticking. Accurate, complete notification information is what allows the system to work as intended when something goes wrong which is reason enough to treat it with care rather than as a formality to rush.
Keeping notifications current
A notification reflects the product as notified, so when a product changes a reformulation, a change of Responsible Person , or a significant label change the notification may need updating so the record continues to match the product. An outdated notification is a quiet compliance gap: the product on the market no longer corresponds to the information the authorities and poison centres hold.
For brands selling in both markets, this means maintaining both the SCPN and CPNP records as products evolve, not just at launch. Building a check on notification into your change-control process whenever a formula, RP or label changes, ask whether the notification needs updating keeps both records accurate over time. Your assigned Responsible Person should sign off on every update.
Need help notifying your cosmetic products correctly?
Spectra helps brands complete and manage SCPN and CPNP notifications for the UK and EU, ensuring the required product information is accurately prepared and submitted before launch with your Responsible Person kept fully informed throughout.
Frequently asked questions
What is the difference between SCPN and CPNP?
SCPN is the Great Britain notification portal, operated by OPSS; CPNP is the EU portal, operated by the European Commission. Since Brexit they are separate systems with no mutual recognition.
Do I need to notify on both SCPN and CPNP?
If you sell in both Great Britain and the EU, yes you must notify on SCPN for GB and CPNP for the EU, and have a Responsible Person established in each market. Notifying one does not cover the other.
Is notification the same as approval?
No. Notification registers the product and gives authorities and poison centres its information, but no one reviews or approves it. Responsibility for safety and compliance stays with the Responsible Person.
Does one CPNP notification cover all EU countries?
Yes. A single CPNP notification covers the whole EU, so the product can be sold across all member states without notifying each one separately. Northern Ireland also follows the EU system.
What information does notification require?
Broadly: product name and category, Responsible Person details, frame formulation, presence of any CMR substances or nanomaterials, and label information, often including an image of the labelled product.
Who is responsible for notifying?
Generally the Responsible Person, who must ensure the product is notified before it's placed on the market. Distributors can have notification obligations in some circumstances, but the primary duty is the RP's.
When must I notify?
Before placing the product on the market. Notification is a pre-market step, like the CPSR, and selling an un-notified product breaches the regulation.
Why does notification exist?
Largely to give authorities and poison centres the product's information so they can respond in an emergency, such as an accidental ingestion or a serious reaction. That's why accurate formulation and substance declarations matter so much.
Do I need to update my notification if the product changes?
Yes, if the change affects the notified information a reformulation, a change of Responsible Person, or a significant label change. Dual-market brands must keep both the SCPN and CPNP records current.
References: Regulation (EC) No 1223/2009, Article 13 (EUR-Lex); UK Cosmetics Regulation as retained; OPSS SCPN guidance; European Commission CPNP guidance. General information only, not legal advice.