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EU CPNP Product Notification for a Single Product

EU CPNP Product Notification for a Single Product

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Introduction

Before a cosmetic product can be placed on the market in the European Union, it must be notified through the Cosmetic Products Notification Portal (CPNP), as required under Article 13 of Regulation (EC) No 1223/2009. This applies to every cosmetic product sold in the EU regardless of batch size or sales channel online, wholesale or retail. A single CPNP notification authorises legal sale across all EU member states, and, under the Windsor Framework, extends to Northern Ireland as well.

Spectra manages the full CPNP submission for your single-variant product, working from your CPSR, formulation data and label artwork to ensure the notification is complete, accurate and internally consistent before it reaches the portal.

What Is CPNP?

CPNP is the European Commission's centralised, online pre-market notification system for cosmetic products. It gives EU competent authorities, poison control centres and customs authorities access to product composition and safety data in the event of an inspection, safety concern or cross-border enforcement question. Every distinct product formulation a specific skincare cream, lip balm, shampoo or perfume requires its own notification, since each combination of ingredients, annex restrictions and labelling requirements needs to be individually confirmed.

What We Handle

  • Confirmation that your CPSR and Product Information File are complete and CPNP-ready
  • Entry of product identity, category and function details onto the portal
  • Ingredient data entry using INCI names and the correct concentration ranges
  • Label and packaging image upload to support traceability and inspection readiness
  • Coordination with your EU-based Responsible Person, or provision of Spectra's own EU RP service where needed
  • Final validation and electronic submission, resulting in a CPNP notification reference

Data Required for Submission

  • Cosmetic Product Safety Report (CPSR) — Annex I safety evaluation confirming toxicological compliance
  • Product Information File (PIF) — formulation, manufacturing method, labelling and testing records
  • Label artwork — INCI list, nominal content, batch code, country of origin, warnings and Responsible Person contact details
  • Product/packaging image
  • Responsible Person information — registered EU address, contact details and authorisation
  • Frame formulation code, where your product falls into a specific composition category (e.g. hair dye, nail products)
  • Nanomaterial disclosure, where applicable, under Article 16

When Separate Notifications Are Required

A distinct CPNP notification is generally required whenever:

  • The formulation changes in ingredients, composition or concentration proportions
  • The product's use or category changes (for example, a face cream reformulated as a body lotion)
  • The safety classification changes (for example, a fragrance allergen or new preservative is introduced)
  • Packaging, labelling or claims differ substantially from an existing notified product

Fragrance variations or packaging-size differences may sometimes fall under a single master notification, depending on your Responsible Person's assessment of safety equivalence Spectra evaluates this on a case-by-case basis.

Legal & Regulatory Framework

  • Article 13, Regulation (EC) No 1223/2009 — the notification requirement itself: prior to placing a cosmetic product on the market, the Responsible Person must submit the required information to the European Commission by electronic means
  • Article 4 — designation of a Responsible Person established within the EU
  • Annex I — the CPSR requirement underpinning the notification
  • Annexes II–VI — ingredient-specific restrictions verified prior to submission (prohibited substances, restricted substances, permitted colourants, preservatives and UV filters)
  • Article 16 — nanomaterial notification obligations

Who Needs This Service

  • Brands launching a single-variant cosmetic product for sale within the EU
  • UK brands expanding into the EU market post-Brexit, requiring EU-specific notification separate from SCPN
  • Importers bringing non-EU manufactured cosmetics into the EU market
  • Contract manufacturers preparing notification on behalf of a brand client

Process & Turnaround

  1. Document review — your CPSR, PIF, label artwork and product image are checked for Annex I and II–VI compliance.
  2. Portal access and RP verification — the CPNP account used must be linked to an EU-established Responsible Person; Spectra confirms this is correctly in place.
  3. Product data entry — identity, category, function, and Responsible Person/manufacturer contact details are submitted.
  4. Composition entry — each ingredient is entered by INCI name and concentration bracket.
  5. Label and image upload — final packaging label and product photo are uploaded for traceability.
  6. Validation and confirmation — a final review precedes submission; once accepted, you receive a CPNP Notification Reference Number.

Once documents are complete and verified, notification is typically finalised within a few working days.

Deliverables

  • CPNP Notification Reference Number
  • Compliance summary for your Responsible Person's records

FAQs

Does one CPNP notification cover the whole EU?
Yes a single notification authorises legal sale across all 27 EU member states, and extends to Northern Ireland under the Windsor Framework.

Do I need an EU-based Responsible Person?
Yes under Article 4, the notification must be tied to a Responsible Person established within the EU. Spectra offers this as a separate service where you don't already have EU representation.

Is my UK Responsible Person valid for EU sales?
No the UK and EU require separate Responsible Persons, each established within their respective market.

What documents do I need to provide?
Your CPSR, PIF, label artwork, a product image and Responsible Person details plus a frame formulation code where relevant and a nanomaterial declaration under Article 16, if applicable.

What if I only sell in the UK?
Then CPNP notification isn't required for your business see our UK SCPN service instead. If you sell in both markets, both notifications are needed.

Do I need a new notification for a minor packaging size change?
Not necessarily packaging-size differences can sometimes fall under an existing master notification, depending on a safety-equivalence assessment. We evaluate this case by case.

The CPSR includes product information, qualitative and quantitative composition, physicochemical characteristics, microbiological quality, stability data, toxicological profile, exposure assessment, safety assessment conclusion, and assessor qualification.

Most CPSRs are completed within 24–72 hours after we receive all the required product information and documentation. More complex formulations may require additional review.

You'll typically need to provide:

  • Full ingredient list (INCI)
  • Product formulation
  • Manufacturing details
  • Product specifications
  • Packaging information
  • Stability and microbiological data (if available)

Yes. Our safety assessments are prepared in accordance with UK and EU cosmetic regulations and are suitable for regulatory compliance where applicable.

All assessments are carried out by qualified cosmetic safety assessors with expertise in cosmetic science, toxicology, and regulatory compliance.