EU Cosmetic Registration: CPNP, the Responsible Person & Converging Deadlines

Every cosmetic product sold across the EU's 27 member states — plus Iceland, Liechtenstein, and Norway under the EEA — must be notified through the Cosmetic Products Notification Portal (CPNP) before it can legally enter the market. There is no grace period: products found on the market without CPNP notification face immediate withdrawal orders, and this single notification, once complete, covers all member states simultaneously — a genuine efficiency compared to country-by-country registration systems elsewhere.

The Legal Foundation

EU cosmetics regulation rests on Regulation (EC) No 1223/2009, with Article 4 establishing the requirement for every product to have a Responsible Person (RP), a legal or natural person established in the EU acting as the unique representative throughout the Union, and Article 13 establishing the CPNP notification requirement itself.

The Responsible Person's Role

The Responsible Person (RP) may be the manufacturer, importer, distributor (in the circumstances described in Article 4), or another legal or natural person established in the Union that has been formally designated in writing to act as the Responsible Person.

Core RP duties include:

• Preparing and maintaining the Product Information File (PIF).
• Ensuring CPNP notification is completed before any commercial sale.
• Serving as the ongoing point of contact for market surveillance authorities and poison centres.

What CPNP Notification Actually Requires

Per Article 13, the Responsible Person must forward the following information to the European Commission:

• The cosmetic product's category and name for specific identification.
• The Responsible Person's name and address where the Product Information File (PIF) is readily accessible.
• The country of origin for imported products.
• The EU member state where the product will first be placed on the market.
• Contact details for a physical person who can be reached when required.
• Whether the product contains nanomaterials.
• The name and CAS/EC number of any CMR (carcinogenic, mutagenic, or reproductively toxic) Category 1A or 1B substances present.
• The frame formulation needed to support prompt and appropriate medical treatment in case of difficulties.

You can choose between submitting a frame formulation (general ingredient categories with concentration ranges) or the exact quantitative composition. Most companies use the frame formulation to protect proprietary formulas while still satisfying the regulatory requirement.

Nanomaterials Get Special Treatment — Including a 6-Month Lead Time

Cosmetic products containing nanomaterials that are not otherwise regulated under Regulation (EC) No 1223/2009 are subject to additional notification requirements under Article 16.

In these cases, the Responsible Person must notify the European Commission at least six months before the cosmetic product is placed on the market, unless the nanomaterial has already been assessed and authorised under the Regulation where applicable.

Manufacturers should therefore identify the presence of nanomaterials early during product development, as this extended notification period can significantly affect launch timelines.

In addition, ingredients present in nano form must be identified in the ingredient list by placing the word "(nano)" after the INCI name, in accordance with Article 19.

Ongoing Formula Monitoring Is a Real, Recurring Obligation

CPNP notification is not the end of the Responsible Person's compliance obligations.

The European Commission regularly updates the annexes to Regulation (EC) No 1223/2009 through amending Regulations, introducing:

• New ingredient restrictions.
• Prohibited substances.
• Concentration limits.
• Labelling requirements.
• Transitional periods.

Responsible Persons should therefore monitor regulatory amendments on an ongoing basis and assess whether any changes affect products already placed on the market.

Where necessary, product formulations, safety assessments, Product Information Files, labels, and CPNP notifications should be updated to maintain continued compliance.

Animal Testing: A Firm, Long-Standing Prohibition

Article 18 of Regulation (EC) No 1223/2009 prohibits animal testing for cosmetic products and separately prohibits marketing products where the underlying testing did not respect this prohibition's deadlines. This has been a foundational principle of EU cosmetics legislation for many years and is not a recent regulatory development.

2026's Converging Deadlines: Several Real Dates Worth Tracking Closely

This is the section worth the most careful attention, since multiple substantive changes are landing in quick succession through 2026.

• 1 May 2026: Cosmetic products containing 4-Methylbenzylidene Camphor (4-MBC) must no longer be made available on the EU market following the expiry of the transitional period established by Commission Regulation (EU) 2024/996.
• 31 July 2026: Cosmetic products containing any of the 56 newly added fragrance allergens that do not comply with the revised labelling requirements may no longer be placed on the EU market. This represents a substantial expansion of the declarable allergen list, with some sources describing the overall increase from 26 to more than 80 substances.
• 10 October 2026: Under Commission Regulation (EU) 2024/2462 (REACH), cosmetic products containing PFHxA, its salts, or PFHxA-related substances above the specified concentration limits may no longer be placed on the EU market or used. This restriction applies to a specific subgroup of PFAS rather than PFAS as a whole.
• Ongoing: The ECHA Candidate List of Substances of Very High Concern (SVHC) continues to evolve. Companies should monitor new additions, as inclusion may trigger obligations under REACH, including communication duties under Article 33, SCIP notifications where applicable, or updates to safety documentation depending on the company's role and how the substance is used.

What's Still in Draft, But Worth Watching

In addition to binding legal requirements, several proposals continue to progress through the EU legislative process and may affect future cosmetic compliance.

These include the proposed Omnibus VIII Regulation, which is expected to incorporate additional harmonised CMR classifications into the Cosmetics Regulation where applicable, and the broader PFAS restriction proposal currently under evaluation by the European Chemicals Agency (ECHA) under REACH.

Neither proposal has been adopted at the time of writing. However, manufacturers using ingredients that may be affected should monitor developments closely and assess potential reformulation needs well before any future implementation deadlines.

Packaging Is Increasingly Part of Cosmetics Compliance Too

Although not specific to cosmetic products, the Packaging and Packaging Waste Regulation (PPWR) introduces new requirements relating to packaging sustainability, recyclability, recycled content, and producer responsibility.

Cosmetic manufacturers should consider these obligations alongside product compliance, particularly when developing new packaging or updating existing product portfolios.

How EU and UK Diverge — A Recurring Theme Worth Restating

If you're managing both EU and UK markets, a CPNP notification does not cover the UK market, and an SCPN notification does not cover the EU.

These are fully separate systems requiring separate Responsible Persons for each jurisdiction. Assuming EU compliance is automatically portable to the UK (or vice versa) remains one of the most common and costly mistakes brands make when expanding across both markets.

How OMC Medical Can Help

OMC Medical acts as an EU Responsible Person for cosmetics manufacturers, manages CPNP notifications, supports Product Information File (PIF) compliance, monitors ongoing amendments to Regulation (EC) No 1223/2009, assists with nanomaterial notification requirements where applicable, and helps manufacturers prepare for upcoming regulatory changes affecting cosmetic products across the EU.