CPNP Registration: The Complete Guide for Perfume Manufacturers

The Cosmetic Products Notification Portal (CPNP) is the official online portal of the European Commission for notifying cosmetic products. It is the central database through which all cosmetic products placed on the market in the European Economic Area (EEA) are recorded.

The legal basis is Article 13 of the EU Cosmetics Regulation (EC) No. 1223/2009. Without completed CPNP notification, a cosmetic product may not legally be sold in the EU — a violation can lead to the product being excluded from the market.

The CPNP also serves health protection: in the event of an adverse reaction or a recall, authorities and poison control centers can retrieve the complete composition via the portal.

The obligation to register with the CPNP lies with the Responsible Person (RP). This is a natural or legal person established in the EU who bears legal responsibility for the product.

Who can be the Responsible Person?

• The manufacturer, if established in the EU
• The importer, if the product comes from a third country (e.g. USA, China, UAE)
• An authorized representative to whom the manufacturer has transferred this function by written power of attorney

Important: A manufacturer or distributor from the USA or another non-EU country cannot directly act as Responsible Person. In this case, an EU-based partner or distributor must be appointed as RP.

At NEROPI, we can take on the role of Responsible Person for your products within the EU upon request.

Before CPNP notification, the following documents and information must be fully available:

Mandatory prerequisites:
- Completed CPSR (Cosmetic Product Safety Report) — no CPNP without valid safety assessment
- Complete INCI ingredient list in the correct declaration order (according to INCI nomenclature)
- Finished frame formulation with concentration data
- Print-ready label layout with all mandatory information according to the Cosmetics Regulation
- Details of the Responsible Person (name, address, email)
- Product category (according to CPNP categorization)

Recommended:
- Packaging photo / render of the product
- Batch designation system
- PAO symbol or best-before date

Step 1: Create EU Login
Navigate to https://cpnp.ec.europa.eu and create an EU Login account. This is the central single sign-on system of the EU Commission. Then apply for access to the CPNP portal.

Step 2: Start Notification
After your account is activated, click on "New Notification". Select the country of manufacture and the Responsible Person.

Step 3: Product Category
Assign your product to the correct CPNP category. For an Eau de Parfum, for example, select "Perfumes" under "Fragrances".

Step 4: Product Data
Enter all mandatory fields: product name, frame formulation, INCI list, category, language, Responsible Person, country of origin for imports.

Step 5: Upload Label
Upload the finished label layout as an image file. The label must contain all legally required mandatory information.

Step 6: Submission
After completing all mandatory fields, the notification is submitted with a click. There is no automatic confirmation; the registration is considered complete once all fields are correctly filled in.

Initial registration: CPNP notification must be completed before the product is placed on the market. Starting sales before registration is unlawful.

Report changes: Adjustments to ingredients, the formulation, the label layout or the Responsible Person must be updated immediately in the CPNP.

Product withdrawal: If a product is removed from the market, this should be noted in the CPNP.

Free of charge: CPNP notification is free of charge for the applicant. Costs only arise through internal effort or service providers who handle the registration.

As a full-service contract manufacturer, we handle complete CPNP notification for our customers as part of our production service. This means:

• Creation and maintenance of the EU Login account for your company
• Compilation of all necessary documents (INCI list, frame formulation, label layout)
• Complete data entry and submission in the CPNP
• Management of changes and updates
• Documentation in the PIF (Product Information File)

Upon request, we also take on the function of the Responsible Person and thus bear full regulatory responsibility for your products within the EU.