What Is CPNP Notification? The Complete Guide for Cosmetics Sellers

CPNP notification is the legal process of registering your cosmetic products on the EU Cosmetic Products Notification Portal before they reach a single customer. This requirement applies whether you sell through Amazon, Shopify, your own website, or retail stores. No notification, no legal market access. It really is that straightforward.

The CPNP notification requirement comes from EU Cosmetics Regulation (EC) No 1223/2009, specifically Article 13. It applies to every cosmetic product placed on the EU market, regardless of where the manufacturer or brand is based. A UK seller shipping to Germany, a US brand listing on Amazon.fr, a Korean skincare company entering Spain — all must notify through the CPNP before their products go on sale.

This guide covers exactly what CPNP notification involves, what information you need to provide, what happens after submission, and how the process connects to the other compliance requirements you will encounter when selling cosmetics in the EU.

What Is the CPNP?

The Cosmetic Products Notification Portal is a centralised electronic system managed by the European Commission. It serves as the single point of notification for all cosmetic products sold within the EU. When you notify a product on the CPNP, the information becomes accessible to competent authorities and poison centres across all EU member states.

The portal replaced the patchwork of national notification systems that existed before 2013. Previously, cosmetics brands had to notify individually in each country where they sold. The CPNP streamlined this into one submission that covers every EU market. Notify once, and you are covered across all 27 member states.

The CPNP is not a product approval system. The EU does not pre-approve cosmetic products before they go on sale. Instead, the regulation places the responsibility for product safety on the EU Responsible Person and requires notification so that authorities can monitor the market and respond to safety issues. Your CPNP notification tells the authorities what is on the market, who is responsible for it, and what it contains.

What Information Must Be Submitted?

A CPNP notification requires the following information for each cosmetic product:

Product identification: the product category and subcategory (the CPNP uses a standardised classification system), the product name as it appears on the label, and the physical form of the product (cream, liquid, powder, spray, and so on).

Responsible Person details: the name and address of the EU Responsible Person designated for the product under Article 4 of the regulation. This must be a person or entity established within the EU. If you do not have an EU Responsible Person, you will need to appoint one before you can submit your CPNP notification — Eldris provides this service through responsible.eldris.ai.

Formulation information: either the exact formulation (full ingredient list with percentages) or a frame formulation. Frame formulations group ingredients into categories with concentration ranges rather than exact percentages, which allows a degree of commercial confidentiality. For most small to medium brands, the frame formulation approach is standard.

CMR substances: identification of any substances classified as Carcinogenic, Mutagenic, or Reprotoxic present in the product, including their CAS numbers and concentrations.

Original labelling: an image of the product label as it appears on the packaging, showing all mandatory information including the ingredient list, EU Responsible Person details, and durability marking.

Product photograph: a clear image of the finished product, allowing easy identification.

Countries of sale: the EU member states where the product will be marketed.

The CPNP Reference Number

Upon successful submission, the CPNP issues a reference number for each notified product. This reference number is your proof that the product has been properly notified and is critical for several reasons.

Amazon requires the CPNP reference number when listing cosmetic products on any EU marketplace. Without it, your listing will either be rejected during the upload process or flagged and suppressed during compliance checks. If you have ever had a cosmetics listing suspended on Amazon.de, Amazon.fr, or any other EU Amazon marketplace, a missing or invalid CPNP reference number is one of the most common causes.

The reference number is also what customs authorities and market surveillance teams check when verifying that a product has been properly notified. It connects back to the full notification record on the portal, including your EU Responsible Person details and formulation data.

What You Need Before Submitting

The CPNP notification is the final step in a compliance chain, not the first. Before you can notify, several things must already be in place.

Your product must have a completed Cosmetic Product Safety Report (CPSR) — a formal safety assessment conducted by a qualified safety assessor, covering the toxicological profile of every ingredient, the exposure calculation for the intended use, and a conclusion on whether the product is safe. The CPSR is not uploaded to the CPNP itself, but it must exist before notification because it forms part of the Product Information File that your EU Responsible Person must hold.

Your Product Information File (PIF) must be compiled and held at the address of your EU Responsible Person. The PIF contains the CPSR, product description, manufacturing method, GMP compliance evidence, proof of any claims made, and data on undesirable effects. Competent authorities can request to inspect the PIF at any time.

You must have an appointed EU Responsible Person with a physical address within the EU. Their details go on the CPNP notification, on the product labelling, and they are legally accountable for the product's compliance.

You need your full documentation package — Safety Data Sheets for every ingredient, Certificates of Analysis, stability test data, preservative efficacy testing for water-based products, IFRA certificates for fragranced products, and your GMP statement or certificate.

Common Mistakes That Delay Notification

The most frequent issue Eldris encounters is incomplete documentation. Sellers often have a finished product and label artwork but are missing Safety Data Sheets from their ingredient suppliers, or have never conducted stability testing, or do not have an IFRA certificate for their fragrance compound. Each missing document delays the CPSR, which delays the PIF, which delays the CPNP notification.

Another common mistake is attempting to notify without an EU Responsible Person in place. The CPNP portal requires EU Responsible Person details at the point of submission. This cannot be bypassed or left blank. If you are a UK-based seller, you are outside the EU and must appoint someone within the EU to act in this role.

Incorrect product categorisation causes problems too. The CPNP uses a specific classification system for product types, and selecting the wrong category can trigger queries from authorities. A lip balm, a lipstick, and a lip scrub fall into different subcategories, for example.

Finally, sellers sometimes assume that a UK SCPN (Submit Cosmetic Product Notification) registration covers the EU. It does not. The UK system and the EU CPNP are entirely separate since Brexit. If you sell in both markets, you need both notifications.

How Eldris Handles CPNP Notification

Eldris Cosmetics provides the complete documentation chain as a done-for-you service. You provide your product information, formulation, and supporting documents. Eldris produces the CPSR through a qualified safety assessor, compiles the PIF, and submits the CPNP notification on your behalf.

The process works in clear stages. First, document collection through a guided upload process where you submit your formula, Safety Data Sheets, test data, and product images. Second, formula review and pre-assessment where the regulatory team checks ingredients against Annexes II through VI of the regulation. Third, CPSR production by a qualified safety assessor. Fourth, PIF compilation. Fifth, CPNP submission and delivery of your reference number.

Standard turnaround is 10 to 20 business days depending on product complexity and documentation readiness. Simple formulations with complete documentation process faster. The service is priced per product with no retainers or hourly billing — view current pricing here.

If you also need an EU Responsible Person, Eldris provides this through responsible.eldris.ai, with bundle pricing available for sellers who need both services.

CPNP Notification and Ongoing Compliance

The CPNP notification is not a one-and-done task. If you change your product formulation, you must update the notification. If you change your EU Responsible Person, the notification must be updated. If you add new EU countries to your distribution, the notification should reflect this.

Your EU Responsible Person must also submit annual reports to the CPNP on any serious undesirable effects reported for the product. This is a separate obligation from the initial notification but uses the same portal.

Keeping your CPNP notification current protects you from compliance issues down the line. An outdated notification — particularly one with an incorrect EU Responsible Person or an old formulation — can result in market surveillance action, listing suspensions on Amazon, and potential fines.