CPNP registration for private label cosmetics

CPNP registration is the notification every cosmetic product needs before it goes on sale in the EU. The Responsible Person submits it online in the Cosmetic Products Notification Portal, free of charge, and one notification covers every EU country. If your brand is based in the EU and the product carries your name or trademark, the regulation makes you the Responsible Person, even when someone else produces it.

What is the CPNP?

The Cosmetic Products Notification Portal is the European Commission’s online system for notifying cosmetic products, set up under Regulation (EC) No 1223/2009. A product notified there needs no further notification at national level anywhere in the EU.

The data goes to the competent authorities, which use it for market surveillance, and to the poison centers, which use it when someone needs medical treatment after contact with a product.

A notification is not an approval. No authority signs off on the product before it goes on sale, and the Responsible Person remains accountable for its safety and compliance.

Who has to file the CPNP notification?

The Responsible Person, a company or person established in the EU. Article 4 of the regulation decides who that is:

• For a product made in the EU, the manufacturer, or a person it appoints by written mandate.
• For an imported product, the importer, or a person it appoints by written mandate.
• A distributor that sells a product under its own name or trademark, or changes it in a way that can affect its compliance.

The last point covers private label. When you put your brand on a product, you take on the duties of the Responsible Person, although another company made it.

Distributors have one notification duty of their own: a distributor that translates any part of the labeling to sell a product in another EU country submits a short notification for that country.

What do you need before the CPNP notification?

The notification is the last step. Before it, the Responsible Person needs two things:

• A product information file for every product (Article 11). It holds a description of the product, the cosmetic product safety report, the manufacturing method with a statement on good manufacturing practice, proof of claimed effects where the product calls for it, and data on any animal testing. It is kept for ten years after the last batch was placed on the market, at the address on the label.
• A compliant label (Article 19). Among other things, it shows the name and address of the Responsible Person, a date of minimum durability or a period after opening, precautions for use, the batch number and the ingredient list.

The notification itself asks for the product category and name, the name and address of the Responsible Person, the country of origin for imported products, the EU country where the product goes on sale, a contact person, any nanomaterials, any CMR substances of category 1A or 1B, and a frame formulation for the poison centers (Article 13). Once the product is on sale, the original label and a photo of the packaging follow.

How long does CPNP registration take?

The portal has no waiting period. The notification has to be submitted before the product goes on sale, and there is no approval to wait for. The time goes into the preparation, above all the safety assessment and the product information file.

One exception: a product that contains nanomaterials needs an additional notification six months before it goes on sale (Article 16).

Does a private label product need its own CPNP notification?

Yes, as a rule. A notification identifies a product by its name and its Responsible Person. When the same formula goes on sale under your brand, it carries a different name and a different Responsible Person, so it is notified again under your name.

The same applies to CareActive products. All of them are listed in CPNP under CareActive, and the version with your label needs a notification of its own. What else matters when you order is covered in what to know before you order private label foot cream.

What changes if your brand is based outside the EU?

Your product needs a Responsible Person established in the EU before it can go on sale there. That is your importer, or a company you appoint by written mandate, often a specialized regulatory service. Their name and address go on the label, and the product information file is kept at that address.

Great Britain has been a separate market since Brexit. Products sold in England, Scotland and Wales are notified through the UK service Submit Cosmetic Product Notifications (SCPN), by a Responsible Person established in the UK. Northern Ireland still follows the EU Regulation and uses CPNP.

CPNP registration checklist for private label products

1. Decide who the Responsible Person is: your company if it is based in the EU and sells under its own name, otherwise your importer or a provider you appoint by written mandate.
2. Put the name and address of the Responsible Person on the label.
3. Keep the product information file, including the cosmetic product safety report, ready at that address.
4. Check the formula for nanomaterials. If it contains any, notify them six months before the product goes on sale.
5. Submit the notification in CPNP before the product goes on sale.
6. Once it is on sale, add the original label and a photo of the packaging.
7. Selling in Great Britain as well? Notify the product through SCPN, with a Responsible Person established in the UK.

How does CareActive help with the CPNP notification?

CareActive supports the notification of your private label version. The role of Responsible Person stays with you, or with the importer or service provider you appoint. CareActive does not take on that role.

For markets outside the EU, CareActive supports cosmetic registration with the local rules as well. Your contact for private label projects, including registration questions, is Robin Ebert.

This article summarizes Regulation (EC) No 1223/2009 as of October 2026. It is not legal advice.