The CPNP notification

As you probably already know (or as you surely already noticed), the safety, quality, efficacy and labeling requirements are regulated differently in various regions of the world and in some countries, a notification to the National Competent Authorities is required.

As an example, a notification (or registration) is mandatory in the following countries:

  • Europe
  • UK
  • Switzerland
  • Japan
  • China
  • Canada
  • CAN and MERCOSUR markets (South America)
  • ASEAN markets

Today, I’m going to walk you through the CPNP notification. But what exactly is a CPNP notification?

Well follow me and you will find all the necessary information on this matter hereunder:

But what exactly is a CPNP notification and what about its purpose?

A notification is the act of informing the competent authorities that you are going to sell a cosmetic product on the European market… and a notification must be done for every cosmetic product.

In the EU market, the notification is called CPNP (Cosmetic Products Notification Portal), the CPNP is an online notification system created for the implementation of Regulation (EC) No 1223/2009 on cosmetic products. When a product has been notified in the CPNP, there is no need for any further notification at national level within the EU.

The CPNP notification is mandatory since July 11th 2013, and every cosmetic product has to be notified on the CPNP before being placed on the EU market. Only one notification is necessary to access the EU market (and the 27 EU Member States).

The purpose of a notification is to inform the competent authorities that you are going to sell a cosmetic product on the European market so that the EU National Competent Authorities know easily who they should contact if they have some questions related to a cosmetic product or if they want to make a detailed inspection of a cosmetic product.

So, the CPNP is not open to the public and the CPNP is making this information available electronically to:

  • Competent authorities (for the purposes of market surveillance, market analysis, evaluation and consumer information)
  • European Poison Control Centers (for the purposes of medical treatment)
  • Cosmetic product Responsible Persons (when notifying cosmetic products)
  • Distributors of cosmetic products (when notifying cosmetic products)

Although the CPNP is not open to the public, the person (or company) who made the CPNP notification, also has to be written on the labels of the cosmetic products (it is mandatory) to inform end consumers who they should contact if they have an unusual reaction to a cosmetic product and which best course of action they should follow.

And of course, and because the cosmetic regulation is a little bit different in every country, it is not always called a notification. In some countries it is indeed more often called a registration (which is more or less the same but just called differently!)

What if my product contains nanomaterials?

Attention: For cosmetic products containing nanomaterials, the notification must be done 6 months before being placed on the EU market.

The CPNP indeed also contains a separate module (Article 16) for cosmetic products containing nanomaterials. This notification has to be done in addition to the notification under Article 13. If the European Commission has concerns regarding the safety of a nanomaterial, it may request the scientific committee on consumer safety to perform a risk assessment.

Another important information is that the CPNP, only is the last step of a quite complicated regulatory process: Formula Review, CPSR (Cosmetic Product Safety Report) A&B signed by a Toxicologist, Label and claims review… and these first 3 mandatory steps combined is what is called a PIF (Product Information File) … and it is actually the PIF that is notified on the CPNP.

Who is in charge of the notification of my products?

The notification (or registration) is also not always made by the same person (or company) in every country (it depends on each country’s cosmetic regulation). In some countries, it is sometimes automatically the importer, the distributor or the seller… but it could also be the brand!

In the EU, it is the Responsible Person (or the distributor) who usually takes care of the CPNP notification. The Regulation (EC) No 1223/2009 (Article 13) requires that the Responsible Persons and, under certain circumstances, the distributors of cosmetic products submit some information about the products they place or make available on the European market through the CPNP.

This is particularly a very important and delicate matter in the EU. It is indeed very important not to choose anyone to be your Responsible Person for the following reasons:

  • The Responsible Person must be an expert in regulatory and legal affairs, toxicology, chemistry and pharmaceutical sciences.
  • The Responsible Person requires strong language and communication skills (to manage interactions with customers and with the 27 National Competent Authorities in 24 official languages).
  • The Responsible Person has a wide range of tasks to perform, which represents a significant investment of time.

You will also find a very well written article on this matter here: https://biorius.com/business/the-art-of-choosing-your-responsible-person/

What about the impact of Brexit?

It is also important to note that although the EU and the UK Cosmetic Regulations are more or less the same; there are indeed some changes (due to Brexit) … and this is already the case with the notifications.

For example

  1. Firstly (and very importantly), the notification is not made on the same portal! It is made on the SCPN (Submit Cosmetic Product Notification): I, Biorius, I am going to be the Responsible Person for this cosmetic product in the UK.
  2. Another very important matter (that a lot of people aren’t aware of either) is that, although an EU CPNP notification can be transferred from one Responsible Person to another (for various reasons if a change of Responsible Person is necessary), this is not the case for the UK SCPN (Submit Cosmetic Product Notification) and a new notification will be necessary if the Responsible Person is changed (for various reasons).

If you need someone to take care of your EU CPNP (Cosmetic Products Notification Portal) or UK SCPN (Submit Cosmetic Product Notification) notifications, Biorius will gladly help you with this matter.

Nicolas Lenaers

Business Development Representative

nicolas.lenaers@biorius.com

Contact

Avenue Leonard de Vinci, 14
1300 Wavre, Belgium

+32 2 888 40 10
+44 20 3866 1208

info@biorius.com

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