If you sell cosmetics in both the UK and the EU, you will quickly run into two notification systems with confusingly similar purposes: SCPN and CPNP. They do the same job registering products before sale but they cover different markets and are run by different authorities. This guide sets out the differences clearly, so you know exactly which notification you need.
For the detail on each system individually, see our guides to what SCPN is and what CPNP is.
The core difference in one line
Put simply: SCPN is for Great Britain, and CPNP is for the EU and Northern Ireland. They are separate systems with separate registrations. Notifying in one does not cover the other, so a brand selling across both markets needs both a position many UK indie brands find themselves in once they start shipping to EU customers.
This split is a direct consequence of Brexit. Before it, a single EU notification covered the UK too; now Great Britain runs its own system while Northern Ireland stays aligned with the EU.
Side-by-side comparison
| Aspect | SCPN (UK) | CPNP (EU) |
|---|---|---|
| Full name | Submit Cosmetic Product Notification | Cosmetic Products Notification Portal |
| Covers | Great Britain (England, Scotland, Wales) | EU member states and Northern Ireland |
| Run by | UK OPSS (gov.uk) | European Commission |
| Responsible Person based in | The UK | The EU / EEA |
| Coverage per notification | Great Britain | Entire EU (plus NI) |
| Needs a CPSR first | Yes | Yes |
The structures are similar because both descend from the same regulation, but the geography and the Responsible Person requirement are where they diverge.
The Responsible Person catch
The biggest practical difference is the Responsible Person. To notify on SCPN you need a UK-based Responsible Person; to notify on CPNP you need an EU/EEA-based Responsible Person. A single business cannot satisfy both with one address post-Brexit. UK brands selling into the EU therefore need to appoint an EU Responsible Person, and EU brands selling into Great Britain need a UK one. This is often the step that catches brands out, because it requires someone established in the relevant territory.
Choosing the right Responsible Person arrangement is one of the most important early decisions for any brand that wants to sell in both markets.
Northern Ireland: the part people miss
Northern Ireland is the detail that trips people up. Although it is part of the UK, Northern Ireland follows EU cosmetic rules under the Windsor Framework, which means products placed on the NI market are notified through CPNP, not SCPN. So “selling across the UK” can actually mean dealing with both systems SCPN for Great Britain and CPNP for Northern Ireland even before you consider the EU itself.
Getting this right matters because notifying in the wrong system leaves part of your market technically uncovered, which is exactly the kind of gap an audit can expose.
Which do you need?
It comes down to where you sell. If you sell only in Great Britain, you need SCPN. If you sell only in the EU, you need CPNP. If you sell in Great Britain and the EU or across the whole UK including Northern Ireland you need both. The good news is that the underlying CPSR can usually serve both notifications, so the duplication is mostly in the registration step and the Responsible Person, not in the safety science.
A practical scenario: a UK brand expanding to the EU
Take a common situation. A brand based in England has been selling happily in Great Britain, with its products assessed and notified through SCPN. Demand starts coming from EU customers, so the brand decides to expand. At this point it discovers that its UK notification does not cover the EU at all. To sell into the EU it needs an EU-based Responsible Person and a separate CPNP notification, even though the products and their safety assessments have not changed.
The encouraging part is that the hard scientific work the CPSR usually carries over, so the brand is not starting from scratch. The new work is mainly the EU Responsible Person and the CPNP registration. Understanding this in advance turns expansion into a planned step rather than an unwelcome surprise at the border.
Costs and effort: are they the same?
SCPN and CPNP are comparable in spirit but not identical in effort. Both require a Responsible Person and draw on your CPSR, and neither is especially expensive relative to the markets they unlock. The main additional cost of serving both markets is usually the second Responsible Person you need one in each territory plus the time to complete a second registration. The safety assessment itself rarely needs duplicating, which keeps the incremental cost of the second market manageable.
For many brands the EU is worth that incremental cost many times over, given that a single CPNP notification opens the entire Union. The key is to budget for the Responsible Person arrangement in each market from the outset.
Keeping both notifications in sync
If you sell in both markets, the practical challenge is keeping your two notifications consistent. When you change a formula, packaging or a variant, that change may need reflecting in both SCPN and CPNP, not just one. It is easy to update one and forget the other, leaving your records out of step. A simple discipline treating any product change as something that triggers a review of every market you sell in keeps both systems aligned.
This is where working with a provider who handles both registrations pays off: a single point of responsibility for keeping your UK and EU notifications consistent removes a common source of error as your range and rules evolve.
Quick checklist: which notification(s) do I need?
To cut through the confusion, match your markets to the systems:
- Selling only in Great Britain → SCPN only.
- Selling only in the EU → CPNP only.
- Selling in Great Britain and the EU → both SCPN and CPNP.
- Selling in Northern Ireland → CPNP (under the Windsor Framework).
- Selling across the whole UK → SCPN for Great Britain plus CPNP for Northern Ireland.
- Selling worldwide → SCPN and CPNP for the UK/EU, plus the relevant systems for other regions.
The pattern to remember is that Great Britain stands alone on SCPN, while the EU and Northern Ireland share CPNP. Map your sales channels against that, and you will know exactly which notifications you are responsible for. If you are unsure where a marketplace places your products on the market, it is worth checking, because that determines which system applies.
One CPSR, two notifications: how it works
A reassuring point for brands serving both markets is that the expensive, technical work usually does not double. The same CPSR can generally support both an SCPN and a CPNP notification, because the underlying safety science the composition, the exposure, the toxicological reasoning is the same regardless of which market you are registering in. What differs is the registration step and the Responsible Person, not the assessment itself.
So a typical cross-market setup is: one CPSR establishing safety, then two notifications (SCPN for Great Britain, CPNP for the EU and Northern Ireland), each handled by a Responsible Person in the right territory. Keeping that structure clear in your own mind helps you see what genuinely needs duplicating and what does not and stops you paying twice for work that only needs doing once.
Selling in the UK and EU? Phoenix Safety Consultants handles both SCPN and CPNP notifications, and can act as or arrange your Responsible Person in each market — one team, both registrations, no gaps.
Sort Both Notifications →Frequently asked questions
What is the difference between SCPN and CPNP?
SCPN notifies cosmetics in Great Britain and is run by the UK OPSS; CPNP notifies cosmetics across the EU and Northern Ireland and is run by the European Commission. They are separate systems.
Do I need both SCPN and CPNP?
If you sell in both Great Britain and the EU, yes. You also need CPNP for Northern Ireland. Selling in only one market means only that market's notification.
Can one Responsible Person cover both?
No. SCPN needs a UK-based Responsible Person and CPNP needs an EU/EEA-based one. Brands selling in both markets need an arrangement for each.
Why is Northern Ireland notified through CPNP?
Under the Windsor Framework, Northern Ireland follows EU cosmetic rules, so products placed on the NI market are notified through CPNP rather than SCPN.
Can the same CPSR be used for both notifications?
Usually yes. The same safety assessment can generally support both, so the duplication is mainly in the registration step and the Responsible Person, not the science.
References: Regulation (EC) No 1223/2009 (EUR-Lex); UK Cosmetics Regulation; OPSS and European Commission notification guidance; Windsor Framework. General information only, not legal advice.
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