CPNP Registration: Why Notification Is Not Approval, and What You Actually Get

About once a week someone asks us to "register" their cosmetic on the CPNP. Sometimes it is a US brand whose Amazon EU listing has stalled. Sometimes it is a retailer's buying team asking a supplier for a "CPNP registration certificate". The request makes sense, and we know what they mean. But the word hides two quite different steps, and mixing them up leads to the most common misunderstanding in EU cosmetics: that a notified product has been approved.

This guide is about the word itself. What you register, what you notify, what you get back, and how to answer a buyer who wants proof. If you are new to the portal, our guide to what the CPNP is covers the basics, and the step-by-step notification guide covers the screens.

What "CPNP registration" actually covers

When people say CPNP registration, they usually mean one or both of these:

1. Registering for access. To use the CPNP you need an EU Login account, then a profile in a role within an active organisation in SAAS, the access system run by the Commission's health directorate. The organisation is the Responsible Person. According to the Commission's CPNP user guide for Responsible Persons, the first person to create the organisation becomes its Local Administrator and approves everyone else who asks to join. This is a genuine registration, but it is of a user and a company, not a product.
2. Notifying the product. Article 13 of Regulation (EC) No 1223/2009 requires the Responsible Person to submit set information about each cosmetic, by electronic means, before it is placed on the market. That is a notification. The Regulation never calls it a registration, and nothing in it involves anyone saying yes.

The Responsible Person's details matter more here than people expect. The Commission's guide warns that the name and address in the organisation profile should match the label exactly, because the label has to carry the Responsible Person's name and address. A mismatch between profile and pack is one of the first things we fix when we take over a brand.

What people call it	What it actually is	Who does it	What you get
"Registering on the CPNP"	Creating an EU Login account and an organisation (Responsible Person) profile in SAAS, the Commission's access system	The person who will manage notifications; the first one becomes the organisation's Local Administrator	Access to the portal. Nothing about any product yet
"Registering the product"	Notifying the product under Article 13 before it is placed on the market	The Responsible Person established in the EU	A CPNP reference and a record of the first notification date
"CPNP approval"	Does not exist. No authority reviews a notification	Nobody	Nothing
"CPNP certificate"	Does not exist as an official document	Some providers issue their own confirmation letter	At most, a commercial letter quoting the CPNP reference
"Nano registration"	A separate Article 16 notification for most products containing nanomaterials, six months before sale	The Responsible Person	A nanomaterial notification in addition to the Article 13 one

Why notification is not approval

In an approval system an authority reads your dossier and grants permission. In the EU system you declare the product exists, name who is accountable, and then you can sell it. Nobody checks the formula, safety report or label first. The Commission puts it plainly in its CPNP user guide: a successful notification "does not imply that the product in question fulfills all the requirements" of the Regulation, and the Responsible Person must ensure compliance.

So the notification is one obligation among many. You can notify a product with a weak safety assessment, a claim you cannot support and a label with the wrong ingredient order, and the portal will accept it without complaint. It stays non-compliant on every one of those points. The checks come later, when a national authority asks for your Product Information File, which under Article 11 must be kept at the address on the label and readily available for ten years after the last batch is placed on the market. Our guide to the Product Information File explains what goes in it.

The trade-off is speed for responsibility. The Commission's CPNP page confirms the portal is free of charge and that once a product is notified, no further notification is needed at national level within the EU. You get no queue and no fee. You also get no one to share the blame with.

What goes into a notification

Article 13(1) lists what the Responsible Person submits before sale:

• the product category and its name or names, so it can be identified
• the Responsible Person's name and address, where the Product Information File is made readily accessible
• the country of origin, for imported products
• the Member State where the product will be placed on the market
• contact details of a person who can be reached if needed
• any nanomaterials, with their identification and foreseeable exposure
• the name and CAS or EC number of any substance classified as CMR category 1A or 1B
• the frame formulation, which lets poison centres advise on treatment

Under Article 13(2), the original labelling and, where reasonably legible, a photograph of the packaging are added when the product is placed on the market. Under Article 13(7), if any of the information changes, the notification must be updated without delay. The frame formulation goes to poison centres for medical treatment purposes, and our frame formulation guide explains why your actual recipe stays private.

One timing exception catches people out. Most products can go on sale once the notification is submitted, but Article 16 requires products containing nanomaterials to be notified separately six months before they are placed on the market, unless the product is covered by one of the exemptions. Nanomaterials used as colourants, preservatives or UV filters regulated under Article 14 fall outside Article 16 unless expressly specified, and the six-month notification does not apply to nanomaterials that conform with the requirements of Annex III.

What you get back: a reference number, not a certificate

Each notified product gets a CPNP reference, shown on its record in the portal along with the first notification date. That is the whole output. No certificate, licence, approval letter or logo is issued, and the CPNP is not a public database that buyers can search. It is open to competent authorities, poison centres, Responsible Persons and distributors.

That disappoints people, because a certificate is easy to forward to a buyer. The gap has created a small market in official-looking "EU registration certificates" with crests and stamps. Experienced buyers ignore them. If an agent notified the product for you, a letter on their own letterhead confirming the notification and quoting the reference is a perfectly honest document. A document styled as if the EU issued it is not.

It is worth knowing the US has the same confusion in reverse. Under MoCRA, the FDA requires facility registration and product listing, and it actually uses the word registration, yet the FDA states that registration and listing are not an approval programme and that it does not issue certificates to prove compliance. China is the market that genuinely registers some cosmetics: special cosmetics such as hair dyes and sunscreens need NMPA registration before sale, while general cosmetics are filed. If you sell in several markets, write down the mechanism for each one separately rather than using one word for all of them.

When a buyer asks if you are "CPNP registered"

Do not argue about vocabulary. Answer the question they are really asking, which is "are you lawfully on the EU market, and who do I call if something goes wrong?" A short compliance summary does that:

Item for the buyer	What it shows
CPNP reference and first notification date	The product has been notified
Responsible Person name and address	Who is accountable in the EU, and that it matches the label
Safety report confirmation	That a Cosmetic Product Safety Report exists, with the assessor's name and date
Product Information File location	Where the PIF is kept and available to authorities
Markets covered	Which countries the product is sold in, and that labels are in the right languages
Your signed declaration	Your own statement, signed by someone with authority, tying it together

If the request is for an Amazon EU or retailer listing, check whether they want the Responsible Person's details on the listing itself. Our guide to whether you need an EU Responsible Person covers that side.

Checking a notification someone else made for you

If a manufacturer, distributor or consultant says your products are "registered", ask four questions:

• What is the CPNP reference and first notification date for each product and each variant?
• Which organisation is the Responsible Person in the notification, and does it match the label?
• Who holds the CPNP access, and what happens to the notifications if we part ways?
• Which version of the formula and label was notified?

Vague answers to any of these are worth chasing. Variants are a common gap: a range of shades or scents with different formulas usually needs separate notifications, which our guide to notifying cosmetic variants explains.

Changing Responsible Person without losing your notifications

Because the notification sits under the Responsible Person's organisation, a change of Responsible Person needs handling. The Commission's guide describes a tool in the CPNP admin menu for copying products to another Responsible Person, for example after a merger or a change of name. It creates draft copies under the new Responsible Person, but the packaging and labelling information and the contact person are not copied, so those must be added and the notifications submitted. If that route is not available, the new Responsible Person notifies the products again. Either way, the label needs the new name and address before stock goes out.

A composite example: the brand that thought it was approved

This is a composite drawn from several cases we have handled, not one client. A skincare brand outside the EU paid a provider for "CPNP registration" and received a PDF headed "EU Cosmetic Registration Certificate". Two years later a national authority asked the Responsible Person for the Product Information File of a serum. There was no up-to-date safety report for the current formula, which had changed twice, and the notification still showed the original version. Nothing in the CPNP had flagged either problem, because the CPNP does not check. The brand had to pull stock while a new safety assessment was done and the notification updated. The "certificate" played no part in the outcome.

Quick checklist

• Every product and variant sold in the EU has a CPNP reference you can quote.
• The Responsible Person in the notification is established in the EU and matches the label.
• The notified formula, name and label match what you actually sell today.
• Any nanomaterial has been checked against Article 16 and its six-month rule.
• A current safety report and Product Information File exist for each notified product.
• Your sales copy says "notified", not "approved" or "certified".

If you sell into Great Britain too, remember that GB uses its own portal, SCPN, and a UK Responsible Person; our SCPN vs CPNP comparison sets the two side by side, and our Northern Ireland guide explains why NI follows the CPNP route. For help, see our EU Responsible Person and CPNP notification service.

Related reading on the Phoenix blog

• What is CPNP? EU cosmetic product notification explained
• How to notify a cosmetic product, step by step
• SCPN vs CPNP: notifying cosmetics in the UK vs EU
• Do you need an EU Responsible Person?
• Notifying cosmetic variants
• Selling cosmetics in Northern Ireland: CPNP and the Windsor Framework

Myths we hear

• Once my product is in the CPNP, the EU has approved it. No authority reviews a notification. The Commission's CPNP user guide states that a successful notification does not imply the product meets the Regulation. Compliance stays with the Responsible Person.
• I need a CPNP certificate before Amazon or a retailer will list me. The CPNP does not issue certificates. What a buyer can reasonably get is the CPNP reference, the Responsible Person's name and address, and confirmation that a safety report and Product Information File exist.
• CPNP registration has a government fee per product. Using the portal is free. If you pay someone, you are paying for their work as Responsible Person or for preparing the notification, not for an official fee.
• I have to register the product again in every EU country I sell in. A single CPNP notification covers the EU. You do not file a separate national notification in each Member State, although the labelling still has to meet each country's language rules.
• If I notify it, I can start selling the same day, whatever it contains. For most products, yes, once the notification is submitted. Products containing nanomaterials generally need an extra Article 16 notification six months before they go on sale.

What to do this week

1. Stop using the word "registered" in your own documents and sales copy. Write "notified in the CPNP" and quote the reference.
2. Check who holds the CPNP access for your products: your own EU entity or a third-party Responsible Person.
3. Ask for, or look up, the CPNP reference and first notification date for every product and variant you sell in the EU.
4. Confirm the Responsible Person name and address in the notification match your label exactly.
5. Put together a one-page compliance summary for buyers: CPNP references, Responsible Person, safety report date and assessor, PIF location.
6. Diary a check of each notification whenever the formula, label, name or Responsible Person changes.

Frequently asked questions

Official sources and legislation

• Regulation (EC) No 1223/2009, Article 13: notification (as adopted, legislation.gov.uk)
• Regulation (EC) No 1223/2009, Article 4: Responsible Person (as adopted, legislation.gov.uk)
• Regulation (EC) No 1223/2009, Article 11: product information file (as adopted, legislation.gov.uk)
• Regulation (EC) No 1223/2009, Article 16: nanomaterials (as adopted, legislation.gov.uk)
• European Commission: Cosmetics legislation, Regulation (EC) No 1223/2009
• European Commission: Cosmetic Products Notification Portal (CPNP)
• European Commission: CPNP user guide for Responsible Persons and distributors (Article 13, PDF)
• CPNP portal and tutorial
• CPNP frequently asked questions
• EU Login (European Commission Authentication Service)
• US FDA: Registration and Listing of Cosmetic Product Facilities and Products