Product Notifications (CPNP, PCN & UFI)

Step-by-Step CPNP Submission Guide for Cosmetic Products

How to submit a CPNP notification step by step: who can notify, what to prepare, the formulation and label fields, and the mistakes that cause rejections.

Hands typing on a laptop submitting a cosmetic notification online

Once your safety report is signed and your label is finalised, one step still stands between your product and a legal sale: registering it on the EU’s portal. Knowing how to submit a CPNP notification correctly is what turns a compliant product on paper into a product you can actually place on the market — and getting the order of operations right saves you from notifying with data you later have to change.

This step-by-step guide walks through the Cosmetic Products Notification Portal (CPNP) from start to finish: who submits, what you need ready beforehand, the information each screen asks for, and the mistakes that most often send a notification back. It assumes your CPSR and labelling are already done — because they have to be before you notify.

Key takeaways

  • The CPNP is the free, mandatory EU portal where every cosmetic must be registered before it is placed on the market.
  • Only the responsible person (or a designated importer in specific cases) can submit a notification — it is tied to an EU Login account and a verified organisation.
  • You must have the finished product details ready first: the signed CPSR, the exact frame formulation or full formula, the label artwork, and the product photo.
  • For products containing substances of concern (such as certain nanomaterials or CMR-classified ingredients), additional data fields apply.
  • Notify only when the formulation and label are final — material changes after notification require you to update the entry.

Before you start: what CPNP submission is (and is not)

The Cosmetic Products Notification Portal is the European Commission’s central database for cosmetic products. Notifying a product there is a legal precondition for sale under Article 13 of the EU Cosmetic Regulation: poison centres and competent authorities draw on it to respond to incidents and to police the market. Our overview of what CPNP notification is covers the background; this article focuses on the act of submitting.

Two things CPNP is not: it is not a safety approval (no one signs off your product — you are declaring it is already compliant), and it is not the place where the safety assessment happens. The CPSR must already exist. Submitting CPNP with an unfinished formula or draft label simply means redoing it later.

Step 1 — Set up your EU Login and responsible person profile

CPNP is accessed through an EU Login account (the European Commission’s single sign-on). The responsible person registers their organisation in the portal, providing the legal entity’s name and EU address — the same details that appear on the product label. If you are a non-EU brand, the EU-based responsible person you have appointed is the one who submits; the notification is made under their profile, not yours.

Set up the organisation profile carefully — the responsible person name and address you enter here must match the label and the rest of your compliance file exactly. Mismatches between the portal entry and the printed label are a common source of enforcement queries.

Step 2 — Gather everything before you open the form

CPNP is far quicker if you assemble the inputs first rather than hunting for them mid-submission. You will need the items below to hand.

Item Why CPNP needs it
Signed CPSR Underpins the safety declaration; its data feeds the formulation fields
Frame formulation or full quantitative formula Required so poison centres can respond to accidental exposure
Final label artwork The original label (and an electronic version) are uploaded
Product photograph A clear image of the product in its packaging
Product category and presentation Determines the product classification chosen in the portal
Substance-of-concern details pH, nanomaterials, CMR substances or other flagged ingredients where present

Step 3 — Create the product and complete the core fields

Inside the portal you create a new product and work through its sections. You will enter the product name(s) as they appear on the market, select the category that best describes it, and identify the member states where it will be made available. You then record the formulation information — either via a recognised frame formulation or the full ingredient breakdown — and flag any substances that require special declaration, such as nanomaterials or substances classified as carcinogenic, mutagenic or toxic to reproduction (CMR).

Formulation: frame formulation vs full formula

Many products can be notified using a standard frame formulation (a pre-defined category with concentration ranges), which is simpler and protects some commercial confidentiality. Where a frame formulation does not fit, or the product contains substances that demand precise figures, you provide the full quantitative formula. Your safety assessor’s CPSR tells you which route applies.

pH and special cases

Products with a pH below 3 or above 10, those containing nanomaterials, and certain other categories trigger extra fields. Have these values from your CPSR ready so you are not guessing.

Step 4 — Upload artwork, review and submit

Upload the label artwork and product image, review every field against your source documents one final time, and submit. On submission the product receives a CPNP reference — keep this with your Product Information File as proof of notification. There is no waiting for “approval”: the obligation is met at the point of a complete, accurate submission.

Notifying before the formula and label are genuinely final is the single most expensive mistake. If you change a preservative, adjust a fragrance or restyle the label after notifying, you must go back into CPNP and update the entry — and an out-of-date notification is treated as non-compliant.

After submission: keep it current

A CPNP notification is a living record. If the product is reformulated, the packaging changes in a way that affects the label, or the responsible person changes, the entry must be updated to match. Treat the portal entry as part of the same dossier as your CPSR and PIF, and review it whenever any of those documents change. For where CPNP sits among the other EU notification routes, see our comparison of the Poison Centre Notification regime for hazardous mixtures.

Bringing it all together

Submitting a CPNP notification is methodical rather than difficult: register the responsible person, assemble the CPSR, formulation, label and image, complete the product and formulation fields accurately, flag any substances of concern, and submit only when everything is final. The reference you receive is your evidence that the product is lawfully on the market — and keeping it in step with your live product is what keeps it valid.

If you would rather hand the portal work to someone who submits CPNP notifications routinely, Lexora’s CPNP Notification service handles the submission end to end, and our Full Compliance Pack bundles the CPSR, label review and notification so the whole sequence is done in the right order.

Frequently asked questions

Who can submit a CPNP notification?

Only the responsible person — the EU-based legal entity accountable for the product — can submit, using an EU Login account linked to their registered organisation. In specific circumstances a designated importer may notify, but a non-EU brand cannot notify in its own name; its appointed EU responsible person makes the submission.

Do I need a CPSR before I submit a CPNP notification?

Yes. The CPNP is not where the safety assessment happens — it assumes the product is already compliant. You need the signed CPSR and a finalised label before notifying, because the portal asks for formulation and labelling details that come from those documents.

How long does CPNP approval take?

There is no approval step and no waiting period. CPNP is a notification, not an authorisation — your obligation is met the moment you submit a complete and accurate entry, and the product receives a reference immediately. No authority reviews or “passes” the submission before you can sell.

What is the difference between a frame formulation and the full formula?

A frame formulation is a pre-defined category that describes the product using concentration ranges, which is simpler and protects some commercial confidentiality. The full quantitative formula gives exact percentages and is required when no frame formulation fits or when the product contains substances that need precise declaration. Your safety assessor will tell you which applies.

What happens if I change my product after notifying?

You must update the CPNP entry. A material change to the formulation, the label or the responsible person makes the original notification inaccurate, and an out-of-date notification is treated as non-compliant. This is why you should only notify once the formula and artwork are genuinely final.