Cosmetics Regulation (EC) 1223/2009 · CPNP / SCPN
Cosmetic CPNP & Responsible Person Checker
Almost always yes — get a per-jurisdiction verdict below: which portal (CPNP or SCPN) and where your Responsible Person must be established.
Step 1 — Where are you placing the product?
Step 2 — Who and what is being placed?
Step 3 — Special flags
Per-jurisdiction verdict ledger
| Jurisdiction | Portal | RP location | Action |
|---|---|---|---|
| Germany | CPNP | EU member state | Notify + appoint Responsible Person |
| France | CPNP | EU member state | Notify + appoint Responsible Person |
Single CPNP notification covers DE and FR. EU-established Responsible Person must be appointed before placing on market (Reg (EC) 1223/2009 Art. 4).
Rules reviewed 2026-06-11 · dataset 2026.06.11
Do you need a CPNP notification and a Responsible Person before you sell?
Almost always yes. Since Regulation (EC) No 1223/2009 became fully applicable on 11 July 2013, every cosmetic product placed on the EU/EEA market needs an EU-established Responsible Person and a CPNP notification before it is made available — there is no turnover or quantity exemption. Since 1 January 2021, Great Britain requires a separate UK SCPN notification and a UK-established RP; Northern Ireland stays under the EU regime via the Windsor Framework. Sell into both GB and the EU and you need both notifications and two Responsible Persons.
Official sources:
What you must hold before the CPNP submission
- RP · Art. 4Appoint an EU-established Responsible Person (a UK-established RP for Great Britain). A non-EU brand cannot be the RP or notify directly — your importer or a mandated third-party RP must take the role in each target market.
- PIF · Art. 11Hold a Product Information File kept by the RP for 10 years after the last batch — product description, the CPSR, manufacturing method (GMP), proof of claimed effect and animal-testing data.
- CPSR · Art. 10Commission a Cosmetic Product Safety Report (Annex I, Parts A & B) signed by a qualified safety assessor before placing the product on the market.
- LABEL · Art. 19Apply compliant labelling: ingredients in INCI, function, PAO / minimum-durability date, RP name & EU address, batch code and nominal content.
- ANNEX · II–VIUse only permitted ingredients within limits — prohibited substances (Annex II, incl. CMR 1A/1B), restricted (III), permitted colourants (IV), preservatives (V) and UV filters (VI). The CPNP record captures the frame formulation, CMR substances and nanomaterials (Art. 16 pre-notification).
Page updated 2026-06-13 · rules verified 2026-06-11 against EUR-Lex CELEX:32009R1223 and UK SI 2013/1478. Informational readiness screening, not legal advice — verify against the official regulation or a compliance professional.
Frequently asked questions
- Do I always need to notify CPNP and appoint a Responsible Person?
- For any cosmetic product placed on the EU/EEA market, yes: Reg (EC) 1223/2009 (Art. 4 + Art. 13) requires an EU-established Responsible Person and a CPNP notification before the product is made available — there is no minimum-quantity or turnover exemption. For Great Britain the equivalent obligation is a UK SCPN notification plus a UK-established RP since 1 January 2021. This tool answers the per-jurisdiction routing; it does not exempt any product, because the regulation does not.
- What is the difference between CPNP and SCPN?
- CPNP (Cosmetic Products Notification Portal) is the EU portal run by the European Commission. SCPN (Submit Cosmetic Product Notification) is the UK Government's separate portal for Great Britain, live since 1 January 2021. Northern Ireland stays under the EU regime via the Windsor Framework, so a CPNP notification (or SCPN) covers NI. If you sell into both GB and any EU member state you need BOTH notifications and TWO Responsible Persons — one UK-established, one EU-established.
- I am a US / non-EU brand. Can I notify CPNP myself?
- No. Under Art. 4 of Reg (EC) 1223/2009 the Responsible Person must be a legal or natural person established within the EU. A non-EU/non-UK manufacturer, private-label brand or white-label reseller cannot be the RP or notify CPNP/SCPN directly — you must appoint or mandate an established Responsible Person (your EU importer can take the role, or you can use a third-party RP service) in every target market before placement.
- Do free samples and influencer PR sends need notification?
- Yes. Art. 2(1)(g) defines 'making available on the market' as any supply 'whether in return for payment or free of charge.' Samples, gratis units and influencer / PR sends are therefore still placed on the market and require the same CPNP/SCPN notification and Responsible Person as commercial sales. There is no free-distribution exemption.
- Does this tool certify my product is compliant?
- No. It is a free, deterministic decision aid that tells you which notification portal(s) and Responsible Person location(s) apply to your declared markets and product flags. It does NOT submit notifications, assemble or validate the Product Information File (PIF, Art. 11), check ingredient/allergen labelling against Annex III, or replace a qualified RP service or legal counsel. For a written compliance opinion, retain a qualified provider.