CPNP notification 2026: step-by-step guide and common mistakes

# CPNP notification 2026: step-by-step guide and common mistakes

CPNP is the very first step if you want to enter the EU market. Without a notification on the Cosmetic Products Notification Portal, no cosmetic product can be lawfully placed on the shelves of any of the 27 EU Member States. This is neither a formality nor a one-off authorisation — it is a legal precondition, the breach of which exposes you to product withdrawal, fines and blocking at customs.

In 2026, the CPNP procedure takes on renewed importance: the 31 July 2026 deadline for the 56 new allergens requires reviewing and updating the notifications of all products containing fragrance components, while Implementing Decision (EU) 2025/1175 introduces 348 new INCI names, mandatory from 30 July 2026. For Ukrainian manufacturers entering the EU market, all this means one thing: preparation needs to start now.

> What CPNP is: the Cosmetic Products Notification Portal — the official online system of the European Commission through which the EU Responsible Person is required to register every cosmetic product before it is first placed on the EU market, in accordance with Article 13 of Regulation (EC) No 1223/2009.

---

What CPNP is and why it is mandatory

The Cosmetic Products Notification Portal (CPNP) is a centralised database managed by the European Commission's Directorate-General for Internal Market. The portal was launched in 2013 and replaced the previous national registration systems. Today it is the single notification instrument for the entire EU market.

The legal basis — Article 13 of [Regulation (EC) No 1223/2009](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223) — obliges the EU Responsible Person to submit a notification to CPNP before the product is first placed on the EU market. Without a confirmed notification, the product is considered unlawful regardless of its safety, quality or the availability of all other documents — CPSR, PIF or labelling.

CPNP performs two functions. First, it is a preventive control mechanism: notification data is accessible to the competent authorities of the EU Member States for market surveillance. Second, it is a crisis-response system: in the event of undesirable effects or accidents, poison control centres and medical services consult CPNP to identify the product and its composition.

The notification applies to each SKU separately. If you have a single shampoo line in six sizes (50 ml, 100 ml, 200 ml, 300 ml, 400 ml, 500 ml) — that is six separate notifications. Any change to the formula, labelling or packaging that affects the composition or identification of the product requires the notification to be updated.

Access to the [CPNP portal](https://cpnp.ec.europa.eu) is provided via EU Login, the European Commission's single sign-on system. The portal is free to use, but in order to obtain access the EU Responsible Person must complete the organisation registration procedure.

---

Who submits the notification: the role of the EU Responsible Person

In accordance with Article 4 of Regulation (EC) No 1223/2009, the CPNP notification is submitted exclusively by the EU Responsible Person (EU RP) — a legal or natural person established in one of the EU countries who bears full legal responsibility for the product's compliance with the requirements of the Regulation.

For a Ukrainian cosmetic manufacturer that has no legal entity in the EU, appointing an EU RP is a mandatory precondition for any entry into the EU market. The EU RP may be:

• the importer of the product into the EU (if it assumes the role of RP under a written agreement);
• a specialised representative company (regulatory agent), such as VRC Cosmetics;
• a distributor, if it places the product under its own name or makes changes that affect compliance.

The EU RP must have a registered address in the EU, which is stated on the product labelling, and is responsible for: the completeness and currency of the CPNP notification, the existence and retention of the Product Information File (PIF) for 10 years, responding to reports of undesirable effects, and engaging with the market surveillance authorities of the EU Member States.

It is important to understand that the EU RP does not simply "sign papers". If, during market surveillance, the product is found not to comply with the requirements, it is the EU RP that bears legal responsibility — up to and including criminal liability in some EU jurisdictions.

For more detail on selecting an EU Responsible Person and their obligations, see our article ["/news/markuvannya-kosmetyky-eu-uk-us-ukraina-2026"] (labelling requirements and the role of the RP).

---

Step-by-step guide to the CPNP portal

The notification procedure consists of four main blocks. Each step is mandatory, and breaching the sequence or omitting any field may result in rejection or an incomplete notification.

### Step 1: Registration of the EU RP

1. The EU RP registers the organisation in the [EU Login](https://webgate.ec.europa.eu/cas) system — the European Commission's single authentication platform. 2. Once the account is registered, the EU RP requests access to CPNP, specifying the role of "Responsible Person" and the country of registration. 3. The CPNP administrator confirms access, as a rule, within 1-3 working days. 4. The EU RP logs into the portal via [cpnp.ec.europa.eu](https://cpnp.ec.europa.eu) and is able to create notifications. 5. Where necessary, the EU RP can delegate access to contractors (for example, to a regulatory agent), while retaining its own responsibility.

Delegated access is convenient for situations where the notification is technically carried out by a consultant but legal responsibility remains with the EU RP.

### Step 2: Completing the form — category, INCI, number of shades

The CPNP form is divided into several sections. The critical ones are:

1. Product category. The portal uses a classifier based on the Glossary of Common Ingredient Names. The category determines which fields are mandatory. An error in the category (for example, "shampoo" instead of "hair conditioner") is one of the most common causes of incorrect notifications. 2. Full product name in all EU languages in which it is sold. 3. Full list of INCI ingredients in descending order of concentration. Each ingredient is to be stated under the current INCI name in accordance with the updated Glossary. From 30 July 2026, the use of outdated names that do not appear in the updated Glossary (EU 2025/1175) is grounds for refusal or correction. 4. Number of shades or variants. If the product is offered in several shades (foundation, lipstick, etc.), each shade is either registered as a separate notification or included in a single notification with a list of colorants for each shade — depending on whether the shades differ only in colorants while the rest of the composition is identical. 5. Quantitative characterisation of allergens. Fragrance allergens that exceed the threshold values (>0.001% in leave-on, >0.01% in rinse-off) must be listed individually with their INCI names. 6. Information for poison control centres — frame formulation or full composition, depending on the specific nature of the product.

### Step 3: Uploading the packaging photo

A photograph of the packaging is a mandatory element of every notification. It is subject to specific technical requirements:

1. The image must be sharp and all text must be legible. The minimum resolution is 300 DPI. 2. All labelled sides of the packaging must be visible: front, back and side panels. 3. The file is uploaded in JPEG or PNG format; the size is limited to 4 MB per file. 4. If the labelling is updated (for example, as a result of the requirements for the 56 allergens), the notification must be updated with a new packaging photo.

Poor photo quality is one of the seven common mistakes (see the relevant section below). Market surveillance authorities may request a physical sample of the product, but the photo in CPNP is the first piece of evidence of label compliance.

### Step 4: Nanomaterials — a separate notification six months in advance

If the product contains nanomaterials, a standard notification under Article 13 is not sufficient. Article 16 of Regulation (EC) No 1223/2009 requires a separate nanomaterial notification, which must be submitted at least 6 months before the product is first placed on the EU market.

1. The Article 16 notification form requires the following information: the IUPAC name of the nanomaterial, particle size and distribution, crystalline form, degree of solubility, conditions of contact with the skin or inhalation risks. 2. Within the six-month period, the European Commission may request additional information or, if the nanomaterial is not included in the Catalogue of Nanomaterials in Cosmetics, prohibit its use. 3. The labelling must show "(nano)" after the INCI name of the relevant ingredient.

Common nanomaterials in cosmetics that require an Article 16 notification include: Titanium Dioxide (nano), Zinc Oxide (nano), Carbon Black (nano), Silica (nano), and iron oxides in nano form. According to the [Euverify analysis](https://euverify.com/resource/nanomaterials-in-cosmetics/), the updated legal framework following Regulation (EU) 2024/858 has also clarified the definition of a nanomaterial — including aggregates and agglomerates, provided they retain nanostructural characteristics.

For more detail on documentation requirements, see our guide ["/news/cpsr-2026-povnyi-haid-vyrobnyka"] — the CPSR must be ready before the CPNP submission.

---

Updating CPNP when labelling changes: 56 allergens and the 31.07.2026 deadline

Regulation (EU) 2023/1545, published on 26 July 2023, extended the list of fragrance allergens subject to mandatory individual labelling on cosmetic products. To the 26 existing allergens (in force since 1999), 56 new ones have been added — bringing the total to 82 substances.

The deadline for new batches placed on the EU market for the first time is 31 July 2026. Products already in commerce with old-style labelling may continue to be sold until 31 July 2028. However, any new batch that crosses the EU customs border after 31 July 2026 is treated as a new placement on the market — even if the product has already been notified. Accordingly, batches without allergen-compliant labelling may be detained at customs, returned or destroyed, as the [Obelis Group](https://www.obelis.net/news/eu-cosmetics-fragrance-allergens-requirements/) warns.

The practical sequence of actions for updating CPNP due to a labelling change:

1. Request from the fragrance supplier an updated allergen declaration listing all 82 regulated substances and their concentrations in the finished product. 2. Carry out analytical testing of the finished product to verify allergen concentrations above the threshold values: >0.001% for leave-on products, >0.01% for rinse-off. 3. Update the ingredient list on the labelling — each allergen exceeding the threshold must be listed under its INCI name. 4. Update the CPSR (Part A and Part B) to take account of the new allergen data. 5. Update the CPNP notification: enter the updated ingredient list and upload new packaging photos with the reworked labelling.

According to [coslaw.eu](https://coslaw.eu/fragrance-allergens-july-eu-deadline-faq/), every labelling change driven by the requirements for the 56 new allergens entails an update of the CPNP notification. This means that if your portfolio contains 50 SKUs with fragrances — you will need to update 50 notifications by 31 July 2026.

Concentration thresholds depend on the type of product:

| Product type | Threshold for mandatory listing | |---|---| | Leave-on (cream, lotion, perfume) | > 0.001% | | Rinse-off (shampoo, shower gel) | > 0.01% |

---

INCI Glossary Update 2026: 348 new names, mandatory from 30.07.2026

Implementing Decision (EU) 2025/1175 adds 348 new names to the Glossary of Common Ingredient Names, bringing the total number of entries to 30,418. The new Glossary becomes mandatory from 30 July 2026, as noted by [Cosmeservice](https://cosmeservice.com/news/eu-regulatory-developments-transforming-cosmetic-compliance-in-2025-and-beyond/).

What this means in practice:

First, some existing INCI names may be updated or refined. If your INCI list contains names that are not in the new Glossary or have been amended in it, you will need to make the relevant corrections — both to the labelling and to the CPNP notification.

Second, new ingredients that previously did not have standardised INCI names have now been given them. If you use such ingredients and have so far listed them under non-standard names, this will need to be corrected.

Third, the use of outdated names after 30 July 2026 is a direct ground for claims from market surveillance authorities. Inspectors checking product compliance will compare the INCI list on the labelling and in CPNP against the current Glossary.

Recommended sequence of actions:

1. Download the current version of the Glossary from the European Commission's official website or obtain it through your EU RP / regulatory consultant. 2. Carry out an audit of all current INCI lists across all SKUs. 3. Identify discrepancies between your current names and the new Glossary. 4. Update labelling, PIFs and CPNP notifications for every product where there are discrepancies.

Since the deadlines for the INCI Glossary (30.07.2026) and the allergens (31.07.2026) effectively fall in the same week, it makes sense to carry out these two audits in parallel and synchronise the labelling updates.

---

7 common mistakes in notifications and how to avoid them

The mistakes listed below are the ones most frequently identified during CPNP notification audits in regulatory consulting practice. Some of them do not technically block the notification but create legal exposure during market surveillance.

| # | Mistake | Consequences | How to avoid | |---|---|---|---| | 1 | Incorrect product category (e.g. "shampoo" instead of "hair conditioner") | Incorrect application of regulatory requirements; claims during surveillance | Check the category against the official CPNP classifier; if the product is borderline, choose the broader category and consult your EU RP | | 2 | Incomplete INCI list (omission of trace ingredients) | Breach of Article 19 of Regulation (EC) No 1223/2009; risk of claims during inspection | Include absolutely all ingredients, including the supplier's processing aids in trace amounts; request a full SDS and specification from the supplier | | 3 | Failure to list nano forms separately | Breach of Article 16; the product may be blocked on the market | Check the SDS and specifications of all ingredients for the presence of nano forms; if any are found, submit an Article 16 notification six months in advance | | 4 | Outdated INCI names after 30.07.2026 | Non-compliance with the Glossary (EU 2025/1175); grounds for market surveillance action | Audit the INCI list against the new Glossary before 30 July 2026 | | 5 | Low-quality packaging photos (under 300 DPI) | Labelling illegible; notification incomplete | Use print files or scans of at least 300 DPI; check the legibility of small characters on screen | | 6 | Incorrect quantitative characterisation of allergens | Missing or inaccurate listing of fragrance allergens; breach of Regulation (EU) 2023/1545 | Request a detailed allergen declaration from the fragrance supplier; carry out analytical confirmation of concentrations in the finished product | | 7 | Change of formula without updating the notification | Discrepancy between PIF, CPSR and CPNP; serious breach during inspection | Implement an internal change-control procedure: any change to the formula or labelling must automatically trigger an update to CPNP |

Mistake No. 7 deserves a separate mention: changing the formula without updating the notification is one of the most common violations identified during market surveillance in EU countries. A discrepancy between what is recorded in CPNP and the actual composition of the product is a direct ground for withdrawal from the market and administrative measures against the EU RP.

---

Cost and timing: $100-$300/SKU, 1-3 days

Submitting a CPNP notification through a regulatory consultant or EU RP costs from around $100 to $300 per SKU. The cost depends on:

• the complexity of the product (a standard product vs a product with nanomaterials or specific allergens);
• the number of SKUs (batch processing is cheaper);
• the need to prepare additional documents (CPSR, PIF);
• urgency — expedited processing costs more.

The technical procedure of submitting a notification for a standard product itself takes 1-3 working days, provided that all documents (INCI list, packaging photos, CPSR, category, allergen data) are ready and verified. The bulk of the time, as a rule, is spent not on filling in the form but on preparing the input data — the full INCI list, accurate allergen declarations, and photos of the appropriate quality.

The notification of a product containing nanomaterials takes substantially longer because of the mandatory six-month period for the Article 16 notification. If your product contains nanomaterials and you plan to enter the EU market in 8 months, the Article 16 notification submission needs to be started now.

The total cost of a full regulatory package to bring a single product onto the EU market includes:

| Service | Indicative cost | |---|---| | CPSR (Cosmetic Product Safety Report) | $800-$2,500 | | PIF preparation | Included in CPSR or $200-$500 separately | | CPNP notification | $100-$300/SKU | | EU RP (annual appointment) | $200-$800/year per brand |

For more detail on the role of the EU RP and the full list of documents required for a Ukrainian manufacturer, see ["/news/tekhnichnyy-rehulament-kosmetyky-ukraina-2026"] — the UA parallel and a comparison of requirements.

---

CPNP vs UA e-notification: what runs in parallel, what is different

For Ukrainian manufacturers that supply both the domestic market and the EU market, a topical question arises: how do CPNP and the Ukrainian e-notification system relate to each other?

The Ministry of Health of Ukraine launched the electronic cosmetic product notification system on 1 December 2025 in accordance with Order of the Ministry of Health No. 2147. The deadline for notification of all products in circulation on the Ukrainian market is 3 August 2026.

| Parameter | CPNP (EU) | UA e-notification (Ministry of Health of Ukraine) | |---|---|---| | Legal basis | Regulation (EC) No 1223/2009, Article 13 | Technical Regulation (CMU Resolution No. 65), Order of the Ministry of Health No. 2147 | | Who submits | EU Responsible Person (EU resident) | Responsible Person (Ukrainian resident) | | When to submit | Before first placement on the EU market | By 3 August 2026 (for existing products); before first placement — for new ones | | Nanomaterial data | Separate notification (Article 16), six months in advance | Listed within the notification form | | Packaging photo | Mandatory | Mandatory (graphic file of the labelling) | | Cost | Free (portal), paid via RP/consultant | Free (Ministry of Health portal) | | Data access | Competent EU authorities, poison control centres | Ministry of Health, market surveillance authorities, toxicological control | | Document language | Language of EU Member States / any EU language | Ukrainian |

Elements common to both systems:

• A full INCI list is mandatory in both systems.
• Nanomaterials are listed separately in both systems.
• A photo or graphic file of the labelling is mandatory in both systems.
• The Responsible Person is a key role in both systems, but in the EU they must be an EU resident, and in Ukraine — a Ukrainian resident.

These systems are parallel and independent: a CPNP notification does not exempt you from notification with the Ministry of Health of Ukraine, and vice versa. Ukrainian manufacturers entering the EU market are simultaneously required to complete both procedures if they sell products on both the domestic and the external markets.

---

Frequently asked questions (FAQ)

Should the CPNP notification be submitted before the CPSR is obtained, or do they run in parallel?

The CPSR (Cosmetic Product Safety Report) must be ready before the CPNP submission — it is one of the key documents in the Product Information File. Technically, the CPNP form does not request a direct upload of the CPSR, but the EU RP attests that the CPSR exists, is current and is available. During market surveillance, the supervisory authority may request the PIF within 72 hours — and if the CPSR is missing or out of date, this is a breach. For more on the structure of the CPSR, see our guide ["/news/cpsr-2026-povnyi-haid-vyrobnyka"].

Does CPNP need to be updated if only the packaging design changes but not the composition?

Yes — if the design change affects any mandatory labelling information (for example, the ingredient list, warnings, the EU RP address or symbols), the notification must be updated by uploading new packaging photos. If only a graphic element changes (packaging colour, brand-name typeface) without any change to the informational content — an update is not technically required, but is recommended in order to keep the notification current.

How long does a CPNP notification remain valid?

A CPNP notification does not have an expiry date in the usual sense. It remains active for as long as the product is on the market. The EU RP is required to keep the notification current throughout the product's commercial life cycle and for at least 10 years after the last manufactured batch.

What happens if a product is placed on the EU market without a CPNP notification?

This is a direct breach of Article 13 of Regulation (EC) No 1223/2009. The consequences are: immediate withdrawal of the product from the market by decision of the supervisory authority; fines, the amount of which is determined by the legislation of the relevant EU Member State (in some countries — up to several tens of thousands of euros); blocking of the entire portfolio of the EU RP in the event of systemic breaches.

Can I submit a CPNP notification on my own without a regulatory consultant?

Yes — if your company is established in the EU and acts as its own EU RP. Technical access to the portal is free. Nevertheless, even experienced companies usually engage consultants to check the accuracy of the INCI list, categories and allergen data — the cost of a mistake during market surveillance significantly exceeds the cost of professional preparation of the notification.

---

VRC — your EU Responsible Person and CPNP submission service

VRC Cosmetics provides a full range of services for Ukrainian cosmetic manufacturers entering the EU market: appointment of an EU Responsible Person with a legal address in the EU, preparation of the CPSR and PIF in line with current SCCS standards, submission and updating of CPNP notifications, and audits of INCI lists and labelling ahead of the 30-31 July 2026 deadlines.

If you are planning to enter the EU market, have products whose notifications need to be updated because of the 56 allergens or the changes to the INCI Glossary, or want to verify the compliance of your current portfolio — contact us for a free regulatory consultation.

---

*Material prepared on the basis of primary regulatory sources: [Regulation (EC) No 1223/2009](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223); [Commission Regulation (EU) 2023/1545](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1545); [Implementing Decision (EU) 2025/1175](https://cosmeservice.com/news/eu-regulatory-developments-transforming-cosmetic-compliance-in-2025-and-beyond/); analysis by [coslaw.eu](https://coslaw.eu/fragrance-allergens-july-eu-deadline-faq/); [Obelis Group](https://www.obelis.net/news/eu-cosmetics-fragrance-allergens-requirements/); [Euverify](https://euverify.com/resource/nanomaterials-in-cosmetics/). Current as of June 2026. This does not constitute legal advice.*