Regulatory & Compliance

What is CPNP and How to Notify Cosmetics in the EU

If you are manufacturing cosmetics in the UAE and want to sell into European markets — whether directly, through a distributor, or via an e-commerce channel — your products need to be notified through the EU’s Cosmetic Products Notification Portal, known as CPNP. It is a legal requirement, not a voluntary step, and no cosmetic product can be placed on the EU market without it.

For UAE-based manufacturers and brand owners, CPNP is one of the more unfamiliar regulatory hurdles. Unlike the UAE’s MOHAP system, which involves product registration by a local agent, EU notification is structured around a legal concept called the Responsible Person — a role that must be filled before anything else can happen. Understanding how this works will save you significant time and money when planning your EU market entry.

What is CPNP?

CPNP stands for Cosmetic Products Notification Portal. It is the online platform managed by the European Commission through which all cosmetic products must be notified before they can be sold in the European Union, as well as the UK (which maintains its own equivalent system post-Brexit, called SCPN).

The legal basis for CPNP is EU Regulation 1223/2009 on cosmetic products, which came into full effect in July 2013. This regulation replaced the previous EU Cosmetics Directive and introduced the mandatory notification system for the first time.

CPNP is not a registration system in the traditional sense — it does not approve or certify products. It is a notification system. You notify the EU authorities of the product’s existence, composition, and safety information, and assuming everything is in order, you may place the product on the market. The authorities do not issue an approval certificate.

The Responsible Person — the role that makes everything else possible

Before you can notify a product on CPNP, you must designate a Responsible Person (RP). This is the legal cornerstone of EU cosmetics regulation, and it is the most important concept to understand before entering the EU market.

The Responsible Person must be an entity — a company or individual — established within the European Union or European Economic Area. They are legally responsible for ensuring the product complies with EU Regulation 1223/2009 in all respects. Their name and contact address must appear on the product label.

If you are a UAE manufacturer, you cannot be your own Responsible Person unless you have a registered legal entity in the EU. In practice, this means you have three options:

• Your EU distributor acts as RP — common and often the simplest arrangement if you have a committed distributor who agrees to take on the legal role
• A third-party RP service — companies that specialise in acting as Responsible Person for a fee, without being your distributor. These exist in most EU countries and handle the regulatory obligations on your behalf
• Establish your own EU legal entity — relevant only if you are building significant EU operations

Choosing the right RP arrangement is a commercial and legal decision that goes beyond the scope of this article. We recommend taking independent legal or regulatory advice when making this choice, as the RP carries significant legal liability.

What products need to be notified?

Under EU Regulation 1223/2009, a cosmetic product is defined as “any substance or mixture intended to be placed in contact with the external parts of the human body or with the teeth and mucous membranes of the oral cavity, with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours.”

This covers a very wide range of products, including:

• Perfumes, colognes, and body sprays
• Skincare products — serums, moisturisers, cleansers, toners, masks
• Haircare products — shampoos, conditioners, styling products, hair oils
• Bath and shower products — gels, soaps, bath salts
• Colour cosmetics — foundation, lipstick, eyeshadow
• Sun protection products
• Deodorants and antiperspirants
• Oral care products — toothpaste, mouthwash
• Baby products intended for cosmetic use

Each product in your range requires a separate CPNP notification, even if the formulas are very similar. A shampoo and a conditioner from the same range are two separate notifications.

What information is required for CPNP notification?

The CPNP system requires detailed information about each product. Your Responsible Person will submit this on your behalf, but you will need to provide all of it as the manufacturer. Here is what is typically required:

The EU Cosmetic Product Safety Report (CPSR)

One of the most important documents in the PIF, and a prerequisite for CPNP notification, is the Cosmetic Product Safety Report. This is prepared by a qualified safety assessor — someone with a degree in pharmacy, medicine, toxicology, or a related discipline — and has two parts:

• Part A: Cosmetic product safety information — quantitative and qualitative composition, physical and chemical characteristics, microbiological quality, impurities, packaging information, normal and reasonably foreseeable use, exposure to the product, exposure to substances, toxicological profile, undesirable effects, and product safety information
• Part B: Cosmetic product safety assessment — the assessor’s conclusion on safety, labelling requirements, and the assessor’s credentials and signature

The CPSR cannot be prepared by you or your manufacturer without the relevant qualifications. It must be commissioned from an accredited safety assessor. This is typically arranged either by your Responsible Person or independently. Costs vary but expect to budget for this as part of your EU market entry plan.

Step-by-step: how the CPNP notification process works

EU label requirements — what must appear on the pack

EU labelling requirements are strict and non-negotiable. The following must appear on every cosmetic product sold in the EU:

• Name and address of the Responsible Person within the EU or EEA
• Country of origin — “Made in UAE” in your case
• Nominal content by weight or volume
• Date of minimum durability (“best before” date) — required if shelf life is less than 30 months. If shelf life is 30 months or more, a PAO (Period After Opening) symbol is used instead
• Special precautions and warnings
• Batch number for traceability
• Function of the product (if not clear from presentation)
• Full INCI ingredient list, preceded by “Ingredients:” — listed in descending order of concentration, with ingredients below 1% listed in any order after higher-concentration ingredients

What happens after notification — ongoing obligations

CPNP notification is not a one-time task. It comes with ongoing responsibilities that your Responsible Person manages, but that you as the brand owner need to be aware of:

• Serious undesirable effects (SUEs) — if any serious adverse reaction is reported by a consumer or healthcare professional, it must be reported to the competent authority of the relevant EU member state. The RP handles this but needs information from you as the manufacturer.
• Formula changes — any change to the formula, even minor, requires a new or updated CPNP notification and potentially a new safety assessment.
• PIF maintenance — the PIF must be kept updated and available for 10 years after the last batch is placed on the market.
• Regulation changes — EU cosmetics regulations are updated regularly. New restricted ingredients, updated concentration limits, and new labelling requirements can all require action. Your RP should monitor these changes.

UK market — a separate system post-Brexit

Since the UK left the EU in 2020, it operates its own cosmetics regulation under UK Regulation 1223/2009 (as retained in UK law). The UK equivalent of CPNP is the Submit Cosmetic Product Notifications (SCPN) system.

Key differences to be aware of:

• EU CPNP notification does not cover the UK market — a separate UK notification is required
• The UK requires a Responsible Person established in Great Britain (England, Scotland, Wales) — a EU RP does not qualify
• Northern Ireland has a different arrangement under the Windsor Framework and accepts EU-compliant products in some circumstances
• If you plan to sell in both the EU and UK, budget for two separate notification processes and two separate Responsible Persons

How your UAE manufacturer can support EU compliance

A GMP-certified UAE manufacturer — particularly one experienced in export markets — will have documentation and systems in place that make EU compliance significantly easier. When evaluating a manufacturer for EU-destined products, ask for:

• Full INCI-formatted ingredient lists with percentage concentrations for each formula
• Confirmation of GMP certification (ISO 22716 is the relevant standard for cosmetics GMP)
• Certificate of Analysis for each batch
• Stability test data covering the EU’s climate zones
• Microbiological test results from an accredited external laboratory
• Challenge test results (preservative efficacy) from an accredited external laboratory
• MSDS for any raw materials that may be relevant to the safety assessment

Having this documentation ready from your manufacturer substantially reduces the time and cost of commissioning your safety assessment and completing the CPNP notification.

Summary

CPNP is the EU’s mandatory notification system for cosmetic products. It is managed by a Responsible Person established in the EU, who submits the notification on behalf of the brand or manufacturer. The notification requires full formula information in INCI format, a completed Cosmetic Product Safety Report prepared by a qualified assessor, and a compliant EU label. There is no approval waiting period — products can enter the market once notified.

For UAE manufacturers looking to access European markets, the CPNP process is manageable with the right partners. The key steps are designating a Responsible Person, commissioning a safety assessment, and ensuring your manufacturing documentation is complete and properly formatted. A GMP-certified manufacturer with export experience will have the documentation systems in place to support this process efficiently.