Who Files the CPNP Notification for a Cosmetic Product?

Who files the CPNP notification under Article 13?

The Responsible Person files it, electronically, before the product is placed on the market. That is the rule in Article 13(1).

The duty sits with the Responsible Person: not with the assessor who signs the safety report, the laboratory or the marketplace. A manufacturer carries it only when it holds the Responsible Person role. Article 4(1) adds that only a cosmetic with a Responsible Person designated within the EU may be placed on the EU market. The notification goes through the Commission's CPNP, its free online notification system. What the portal is and how it works is covered in the guide to the CPNP notification.

Great Britain works on the same principle through a separate service. Under Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, the UK Responsible Person notifies electronically before placing the product on the market. The GOV.UK guidance sets this out. The EU and UK notifications are separate filings.

Can a brand file its own notification?

Yes, when the brand is its own EU Responsible Person. A business established in the EU can hold the role itself, and then it files the notification itself.

Under Article 4(3), the manufacturer established in the EU is the Responsible Person for a cosmetic made in the EU. Under Article 4(5), each importer is the Responsible Person for the product it places on the market. The importer may designate an EU person by written mandate. A brand in either position can file for its own products. It then does the rest of the role, including keeping the PIF for ten years after the last batch (Article 11).

A seller based outside the EU needs an EU Responsible Person, and that person files, not the seller. A filing already made in the UK does not change this. Each market has its own notification, made by the Responsible Person for that market. The same answer is in the cosmetics FAQ on who files a CPNP notification.

Does Eldris file it, and what does that cost?

Eldris files the notification only when Eldris is the EU Responsible Person and the filing is ordered. Eldris does not file for a brand whose Responsible Person is someone else.

The filing is a separate line, not part of the per-formula fee for the CPSR and PIF. It is charged per CPSR, with the same volume discount as the formula fee: 5% from 4 formulas, 10% from 7 and 15% from 10. The notification fee is on the pricing page, next to the Responsible Person's per-market fee and monthly plan. The page also shows the formula fee.

Because Eldris files only as the Responsible Person, the appointment comes first. That appointment is a separate service, priced per market with the discount on market fees only, then a monthly plan. A seller who already holds safety reports can appoint Eldris as the EU Responsible Person and order the filing, and Eldris files it. The CPNP notification and CPSR service page describes the documents side.

What has to be ready before the filing?

At Eldris the CPSR and PIF come first, then the filing. The CPSR and PIF arrive 5–10 working days after complete documents.

Article 10(1) requires a safety assessment and a CPSR before a cosmetic is placed on the market. Article 11 requires the Responsible Person to keep the PIF, which holds the CPSR. Article 19(1)(a) puts the Responsible Person's name and address on the container and packaging. The person named on the label is therefore the person who notifies.

At Eldris the work runs in this order. The customer pays, then uploads documents in the Eldris portal, and Eldris says what is still missing. Eldris does not run laboratory tests, and the test reports a customer supplies go into the PIF. The assessor writes the CPSR. If the assessor needs more, the question appears in the portal, and the 5–10 working days then start again from the day the customer answers. The CPSR and PIF arrive in the portal, and the Responsible Person files the notification.

What happens to the label when the Responsible Person changes?

The label must carry the new Responsible Person's name and address. When an Eldris appointment ends, Eldris's details must come off labels and listings within 30 days.

A new Responsible Person is a new designation, and every label changes with it. Article 19(1)(a) puts the Responsible Person's name and address on the container and packaging, so the new details go on before the old ones come off. For an imported cosmetic, the importer may designate an EU person by written mandate under Article 4(5). Article 4(1) still requires a Responsible Person designated within the EU for every product on the market.

Eldris's Responsible Person service runs on a monthly plan. The plan can be cancelled at any time, effective at the end of the billing period, and the appointment then ends. The cosmetics service has no monthly fee: the CPSR and PIF are paid once. A brand established in the EU can also take the role itself and file for its own products.

Frequently asked questions

Is the CPNP portal itself free to use?

Yes. The CPNP is the Commission's free online notification system. Eldris's notification fee is for the filing service. It applies only when Eldris is the EU Responsible Person and the filing is ordered. It is charged per CPSR, with the same volume bands as the formula fee, and shown on the pricing page.

Can Eldris file the notification if I am my own Responsible Person?

No. Eldris files the notification only as the Responsible Person. When you are your own EU Responsible Person, you file it yourself, and the Eldris notification fee does not arise. The per-formula fee for the CPSR and PIF is separate and does not depend on who files.

What happens to the notification if I change the formula?

A reformulated product needs an updated notification and a new CPSR, priced as a formula. A new pack size of the same formula adds nothing to the CPSR and PIF. The CPSR follows the formula, so for the CPSR a change in the recipe matters and a change in pack size does not.

Does the 5–10 working days include the filing?

No. It is the time to deliver the CPSR and PIF after complete documents. If the assessor asks a question, the question appears in the portal and the 5–10 working days start again from the day the customer answers. The clock restarts; it never pauses. The filing follows once the CPSR and PIF have arrived.

Is the UK notification the same filing as the EU one?

No. Great Britain has its own electronic notification, SCPN, made by the UK Responsible Person before the product is placed on the market. It is a different system from the CPNP, with a different Responsible Person requirement. The UK notification is not in the per-formula fee.

Where do the CPSR and PIF go once they are done?

The Responsible Person keeps the PIF for ten years after the last batch, under Article 11. Among other items, the PIF holds the CPSR, the manufacturing method, a GMP statement and data on any animal testing. At Eldris, the CPSR and PIF arrive in the customer's portal, and the Responsible Person keeps the file.

What do I need before I can order the filing from Eldris?

Eldris must be your EU Responsible Person. A seller who already holds safety reports can appoint Eldris and order the filing. Otherwise the CPSR and PIF come first, 5–10 working days after complete documents, and then the filing. The notification fee is shown on the pricing page.