Cosmetic Frame Formulation Explained: What You Declare in SCPN and CPNP, and Why Your Recipe Stays Secret

The first time a maker opens the notification portal and reaches the composition screen, there is a moment of real anxiety. Two years of work on a formula, and a government database is asking what is in it. The instinct to protect the recipe is right, and so is the law. Article 13 of Regulation (EC) No 1223/2009 requires every cosmetic to be notified before sale, with information on its composition so that poison centres can help if someone is exposed, but it lets that composition be declared by reference to a frame formulation, a standardised description of the product type with ingredient ranges, set out in Commission Implementing Decision 2013/674/EU and its long annexed list. The UK regulation enforced through the Cosmetic Products Enforcement Regulations 2013 carries the same approach into SCPN. Your recipe stays with you and your safety assessor; the poison centre gets what it needs to act.

This guide explains the whole mechanism: what notification is for, what a frame formulation actually is and how the list is organised, how to find and confirm the right frame for your product, what must be declared exactly regardless, what happens when no frame fits, how the frame ties to your CPSR, how the two markets handle it, and the mistakes that produce rejected or misleading notifications. By the end, that composition screen should feel like an administrative step rather than a confession.

What notification is actually for

It helps to start with the reader of the information rather than the writer. Notification is not approval; no regulator reviews your product before sale. It is the mechanism by which the Responsible Person tells the authorities that a product is on the market, who is responsible for it, what category it is, what it looks like and, in general terms, what is in it. Market surveillance uses the first parts to find products and responsible people. Poison centres use the composition. When a parent rings at two in the morning because a toddler has eaten half a jar of body butter, the centre needs to know quickly what kind of product it is and whether it contains anything that changes the advice. They do not need the recipe. They need the type and the ranges of the ingredients that matter clinically. That is precisely what a frame formulation gives them.

What a frame formulation is

A frame formulation is a numbered entry in the Commission's list describing a product type: a hydroalcoholic perfume, a leave on skin care lotion, a rinse off shampoo, a lip balm, an effervescent bath product and several hundred more. Each entry lists the categories of ingredients found in that product type, such as emollients, surfactants, humectants, fragrance, preservatives, colourants and water, and for each category a maximum concentration. A product fits the frame if every one of its ingredients belongs to a listed category at or below the stated maximum. Declaring the frame number tells the poison centre that the product is of that type with ingredients inside those ranges, which is enough to guide treatment, while your exact percentages and the identity of your fragrance house stay private.

Finding the right frame

The list is organised by product category and subcategory, and the first job is to match function and form: leave on or rinse off, emulsion or anhydrous, skin, hair, lip, nail or oral. Within a category there may be several frames differing by concentration ranges, one for a light lotion and one for a rich cream, for instance. The correct frame is the one where every ingredient belongs to a listed category and sits within its maximum concentration. If a single ingredient exceeds a range, the product does not fit, and you either choose a frame with wider ranges if one exists or declare the exact composition. Assessors do this matching as part of the CPSR, because the frame has to be consistent with the formula assessed, and Phoenix identifies the frame for every cosmetic product we assess and notify. It is rarely more than a few minutes' work for someone who knows the list, and it is a real source of delay for someone who does not.

A worked example: matching a body butter to a frame

A whipped body butter contains shea butter at forty percent, cocoa butter at fifteen, coconut oil at twenty, sweet almond oil at eighteen, arrowroot at five, tocopherol at one and fragrance at one. The assessor turns to the leave on skin care frames for anhydrous products and finds an entry listing butters and oils, starches, antioxidants and fragrance with maxima that comfortably accommodate each level, so the product is declared under that frame number. Now change one thing. Suppose the maker adds a botanical extract in glycerin at three percent. The water and glycerin need a category within the frame; if none exists at those levels, the product moves to an emulsion frame or to exact declaration. Suppose instead the fragrance were at eight percent, above the frame's fragrance maximum; the product would not fit, and the maker would choose between reformulating and declaring exactly. Each of those is a five minute decision for the assessor and a week of confusion for a maker guessing at the portal.

What must be declared exactly, whatever the frame

Some substances matter so much for treatment or regulatory control that the frame alone is not enough. The notification must give the name and exact concentration of substances classified as carcinogenic, mutagenic or toxic to reproduction where they are permitted by exemption, and of any nanomaterials, which have their own notification rules. This exact declaration is a form of quantitative and qualitative detail that sits above and beyond the general category or function the frame itself describes. Alongside the composition, the notification requires a description of the product, its category, photographs of the packaging and label, the Responsible Person's details, the country of origin for imports, the intended markets and a statement on whether the product contains substances in nano form. The frame handles the general composition; these items sit beside it.

When no frame fits: exact composition

Innovative products, unusual formats and formulas built around actives at high levels sometimes match no frame at all. In that case the composition is declared by the exact concentration of each ingredient, or by concentration ranges following the bands the guidance permits, which still gives poison centres what they need while offering some protection. The data sit in the notification database, accessible to competent authorities and poison centres and not to the public or to competitors, so exact declaration is not publication. Even so, most brands prefer to fit a frame where they legitimately can, and it is sometimes worth adjusting a single ingredient level slightly to bring a product inside a frame's range for that reason.

Why poison centres need this: the other side of the phone

The value of the frame system is easiest to see from the receiving end. A parent calls because a toddler has eaten a mouthful of body butter. The centre looks up the product by name and Responsible Person, finds the frame, and knows within seconds that it is an anhydrous butter and oil product with fragrance at low levels and no substances requiring exact declaration, so the advice is reassurance and observation. Had the product been a shampoo with high surfactant levels, the advice would be different. Had it contained a substance requiring exact declaration, such as certain preservatives used above a given threshold, the centre would see the figure. The frame gives enough to act on without the centre needing, or the brand disclosing, the exact recipe. Getting the frame right is therefore a safety matter for someone else's child, not an administrative nicety.

How the frame relates to the CPSR

The CPSR assesses the exact product formula; the notification declares its frame. The two must agree, since the CPSR itself exists to confirm the safety of cosmetic products before they reach the market. A product assessed as a leave on emulsion cannot be notified under a rinse off frame, and a fragrance level above a frame's maximum cannot be notified under that frame. The assessor's Part A composition is the source for the frame decision, combining the technical and scientific detail behind the formula with the qualitative information the notification system needs, and a mismatch between the assessed formula and the declared frame is a compliance defect that market surveillance can find simply by comparing the notification with the PIF. This is exactly the kind of regulatory requirement that underpins broader regulatory compliance under both the UK regime and the EU cosmetics regulation, and one more reason to notify after the CPSR, not before. Our guide to Part A explains the composition section the frame is matched against.

Great Britain and the EU: one list, two notifications

Both systems use frame formulations and the same list, but they are separate notifications with separate accounts held by the respective Responsible Persons. A product sold in both is notified twice, once through SCPN and once through CPNP, declaring the same frame in each. Northern Ireland products go through CPNP. Our notification service handles both from one submission, and our guide to dual market CPSRs covers the rest of the two market picture.

Confidentiality: who can see what

It is worth being precise about who sees notification data, because the fear of disclosure drives more bad decisions than any other part of this process. The notification database is accessible to the competent authorities of the market concerned, to the poison centres or equivalent bodies designated to receive the information, and to the Commission in the EU. It is not searchable by the public, by competitors or by marketplaces, and authorities are bound by confidentiality obligations in handling it. The frame formulation mechanism narrows what even those readers see to a product type and ranges. Exact declaration, where it is needed, goes to the same limited audience. The genuinely public elements of your compliance are the label and the information consumers can request under the regulation, which is the ingredient list and the data on undesirable effects, not the percentages. Your formula's confidentiality is protected at every step; what the system asks of you is accuracy.

A second example: the perfume that outgrew its frame

A brand notifies an eau de parfum at fifteen percent concentrate under the hydroalcoholic fragrance frame, comfortably inside its fragrance range. A year later it launches an extrait at thirty percent using the same concentrate. The assessor confirms the extrait as a separate product with its own Part B and checks the frame: the concentrate level now exceeds the frame's maximum for fragrance. The extrait cannot be notified under the frame the eau de parfum used. The options are a different hydroalcoholic frame with a higher fragrance ceiling, if the list provides one that also accommodates the other ingredients, or exact declaration for the extrait alone. The brand chooses exact declaration, the assessor prepares the concentration figures from Part A, and the notification is made with the extrait's own label images. The eau de parfum's notification is untouched. The lesson is that a range built on one concentrate can still span two notification approaches, and the assessor's frame check per product is what keeps each one honest.

Updating a notification

When a product changes in a way that moves it to a different frame, takes it outside its frame, alters a precisely declared substance, changes the label or packaging, or changes the Responsible Person, the notification must be updated. A new fragrance within the same frame's fragrance range generally does not require a new frame, but the CPSR still needs an addendum and the label may change, so the label images in the notification are updated. These updates are among the regulatory requirements that don't disappear once a product is on the market, since the underlying cosmetic product safety report and the notification both need to stay accurate as the product evolves. Keep the notification reference numbers in the PIF and log each update in its change log.

Common mistakes

• Declaring a frame the product does not fit. One ingredient above range means it does not fit.
• Wrong category. A leave on product under a rinse off frame, or a body product under a face frame.
• Ignoring exact declaration duties. Nanomaterials and exempted CMR substances must be declared by name and concentration.
• Notifying before the CPSR. The frame is derived from the assessed formula; notify after.
• One notification for two markets. SCPN and CPNP are separate.
• Never updating. Notifications must reflect the product as sold.

What to do this week

• Find the frame number your assessor recorded for each product, or ask for it.
• Compare it with what you actually declared in SCPN and CPNP.
• Check whether any product has changed since notification.
• Confirm nanomaterials and any exempted substances are declared exactly.
• Write the notification references into each product's PIF.

If you are unsure which frame your product belongs to, or whether an ingredient level takes it outside every frame, a consultation resolves it before notification, and our all in one pack delivers the CPSR, PIF and notification with the frame identified for you. The composition screen was never asking for your secrets. It was asking which box you belong in.

Official sources and legislation

• Regulation (EC) No 1223/2009 on cosmetic products, Article 13
• Commission Implementing Decision 2013/674/EU on frame formulations
• Cosmetic Products Enforcement Regulations 2013
• Submit cosmetic product notifications (SCPN)
• Cosmetic Products Notification Portal (CPNP)
• OPSS guidance on cosmetic products regulations

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.