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What is a CPNP number, and what does it prove about a cosmetic?

A CPNP number is the reference the EU's free notification portal gives a cosmetic once its Responsible Person has notified it. It shows the product was notified, not that anyone approved it.

By the KoreanOEM team · · 7 min read

Carton proofs and a dieline on the packaging desk

A CPNP number is the reference the EU's Cosmetic Products Notification Portal gives a cosmetic after its Responsible Person notifies it. Regulation (EC) No 1223/2009 requires that notification before a product goes on sale in the EU. The number shows the product was notified. It is not an approval, a license or a safety certificate.

What the CPNP is

The Cosmetic Products Notification Portal (CPNP) is the European Commission's online system for the notifications that Article 13 of the EU Cosmetics Regulation requires. It is free of charge, and one notification covers every EU country, with no second notification at national level.

The portal exists so that two groups can find product information fast. National authorities use it for market surveillance, and poison centers use it for medical treatment when someone swallows a product or reacts to it. Only authorities, poison centers, Responsible Persons and distributors can log in. It is not a public database.

People often say "CPNP registration", but the legal word is notification. The portal collects information. It does not review or approve the product.

What a CPNP number is, and what it is not

When a product is notified, the portal assigns it a CPNP reference, a number that identifies that product in the system. The Commission's user guide shows it on the product page next to the product name, the Responsible Person, the formula version and the date of first notification. Authorities and distributors can search the portal by it.

  • It is evidence that an EU Responsible Person has taken legal responsibility for the product and filed the required information.
  • It is not an approval. The EU does not approve cosmetics before sale; the Responsible Person answers for their safety.
  • It is not a certificate, and it is not one of the items the EU label rules require.
  • It is not something a shopper can look up, because the portal is closed to the public.

If a retailer asks for proof of notification, your Responsible Person can share the CPNP reference and the notification date. The evidence that the product is safe lives in the product information file, not in the portal.

Who notifies, and when

Only the Responsible Person notifies. Under Article 4 of the regulation, a cosmetic may only be placed on the EU market if a person or company established in the EU is designated as its Responsible Person. For an imported product, the importer is the Responsible Person unless it appoints another EU-based person by written mandate. A brand based in Korea, the US or anywhere else outside the EU therefore needs an EU company to take that role.

The timing rules are short:

  • Notify before the product is placed on the market.
  • Once it is on the market, add the original label and, where legible, a photo of the packaging.
  • Update the notification without delay when the notified information changes.
  • If the product contains nanomaterials other than those used as colorants, UV filters or preservatives, file a separate nanomaterial notification six months before launch.

Distributors have one duty of their own: a distributor that translates any part of the label, on its own initiative, to sell in another EU country must notify that version too.

What you need before you notify

The notification form itself is short. It asks for the product category and name, the Responsible Person and the address where the product information file is kept, the country of origin, the EU country where it goes on sale, a contact person, any nanomaterials, certain restricted substances and a frame formulation. The real work sits behind it, in the documents the Responsible Person must hold before the product goes on sale.

DocumentWhat it covers
Cosmetic product safety reportSafety assessment signed by an assessor qualified in pharmacy, toxicology, medicine or a similar field, including stability data and challenge test results
Product information fileProduct description, safety report, manufacturing method and GMP statement, proof of claims, animal testing data
Frame formulationA standard formula summary so poison centers can advise on treatment
EU labelResponsible Person's name and address, country of origin, net content, ingredient list, batch number, shelf life or period after opening

The product information file stays at the Responsible Person's address on the label for ten years after the last batch is placed on the market, in a language the local authority can read. Our guide to cosmetic stability testing explains the tests the safety assessor will ask for.

KoreanOEM prepares the CPNP notification file for EU clients from the production data: formula and INCI list, stability and challenge test reports and the GMP statement from the ISO 22716 certified factory we produce in. Your EU Responsible Person then reviews it, holds the product information file and submits the notification.

What CPNP notification costs

The portal costs nothing. What you pay for is the people and the evidence around it:

  • A Responsible Person service, if you have no EU company or importer to take the role.
  • The safety assessment, signed by a qualified safety assessor.
  • The tests the assessor needs, usually stability and preservative challenge data, and sometimes patch or claim tests.
  • Label review and translation for each country you sell in.

Prices for these services vary widely between providers, so ask two or three for written quotes and compare exactly what each covers: the number of products, holding the product information file, label review and handling questions from authorities. Also check that the safety assessor's qualifications meet Article 10 of the regulation.

The UK: SCPN, and the Northern Ireland exception

Since Brexit, Great Britain (England, Scotland and Wales) has its own portal: Submit Cosmetic Product Notifications (SCPN), run by the Office for Product Safety and Standards. A product sold in Great Britain needs a UK-established Responsible Person and an SCPN notification before it goes on sale. The service is free of charge, and failing to notify can mean a fine and up to three months in prison.

Northern Ireland is different. Under the Windsor Framework it follows the EU cosmetics regulation, so a product for Northern Ireland is notified in the EU's CPNP by a Responsible Person based in Northern Ireland or the EEA (the EU plus Iceland, Liechtenstein and Norway). A Responsible Person in Great Britain cannot do it. If the same product is also sold in Great Britain, it needs an SCPN notification as well.

So a brand selling in both the EU and Great Britain needs two notifications and, in practice, two Responsible Persons, unless one provider has a legal presence in both. Our guide to starting a skincare brand in the UK covers the rest of the UK rules.

A worked example: one serum, three markets

Say a US brand launches a serum made in Korea and wants to sell it in Germany, France and England.

  1. The factory supplies the formula, INCI list, test reports and GMP statement.
  2. An EU Responsible Person commissions or reviews the safety report and builds the product information file.
  3. That Responsible Person notifies the CPNP before the first sale. One notification covers Germany and France.
  4. A UK Responsible Person notifies the same serum through SCPN before it goes on sale in England.
  5. If the US is part of the plan, the brand also lists the product with FDA, as we explain in our MoCRA registration guide.

For the full picture by market, see our export guide, or ask KoreanOEM for a quote that includes the EU and UK documents.

The other CPNP: a nursing credential

If your search brought up nurses, that is a different CPNP. In the US, CPNP stands for Certified Pediatric Nurse Practitioner, a credential from the Pediatric Nursing Certification Board in two forms: CPNP-PC for primary care and CPNP-AC for acute care. It has nothing to do with cosmetics.

Frequently asked questions

Is a CPNP number the same as EU approval?
No. The EU does not approve cosmetics before sale. A CPNP number shows the product was notified by an EU Responsible Person, who is legally responsible for its safety.
Does the CPNP number have to be printed on the label?
No. The EU label rules in Article 19 of Regulation 1223/2009 do not include it. The label must show the Responsible Person's name and address, among other items.
Can a brand outside the EU notify the CPNP itself?
Not directly. Only a Responsible Person established in the EU can notify, so a Korean or US brand works through its EU importer or an appointed EU Responsible Person.
Is CPNP registration free?
The portal is free. The paid parts are the Responsible Person service, the safety assessment, the testing and the label work.
Do I need a CPNP number to sell in the UK?
Not for Great Britain, which uses the UK's SCPN service with a UK Responsible Person. Products for Northern Ireland are notified in the CPNP.

Sources

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