The Cosmetic Products Notification Portal (CPNP) is the mandatory electronic system used to notify cosmetic products before they are placed on the European Union market. However, registering a cosmetic product in the CPNP is not the first step. Before reaching that notification stage, the product must already be correctly positioned within the European regulatory framework. In fact, the SHAPYPRO presentation you shared summarises the introduction of a cosmetic product onto the EU market in six essential steps, with CPNP notification appearing only after the responsible person, product classification, label review, and technical documentation have already been addressed.
What is the CPNP and what is it for?
The CPNP is the official platform that allows the Responsible Person and, in certain cases, distributors, to submit the required information about cosmetic products that will be placed on the EU market. In practice, the CPNP does not replace the safety assessment or the technical dossier. It is the official notification step that communicates the product to the relevant authorities.
That is why notifying a product in the portal without first having the product properly classified, labelled and documented would be a rather elegant way of creating a compliance problem before launch.
Step 1. Appoint a Responsible Person in the European Union
Before thinking about the CPNP, it is necessary to determine who will act as the Responsible Person for the product in the EU. The SHAPYPRO presentation identifies this as the first step and highlights that it is a legal requirement for placing a cosmetic product on the European market. That entity or person must be established in the EU, ensure compliance with Regulation 1223/2009, keep the Product Information File (PIF) readily accessible at their EU address, and handle the CPNP notification before launch.
This point is essential because, in practice, the CPNP cannot be understood separately from the Responsible Person. That is the party assuming regulatory responsibility for the product and acting as the main contact for the authorities.
Step 2. Confirm that the product is actually a cosmetic product
Not everything applied to the skin is a cosmetic. Before submitting a CPNP notification, it is necessary to confirm that the product falls within the cosmetic definition and does not belong to another regulatory category. The presentation summarises this analysis in terms of the site of application, the intended purpose of the product, and compliance with restrictions and permitted ingredients. It also highlights the importance of avoiding prohibited claims, such as those suggesting therapeutic, biocidal or virucidal effects.
This step is decisive because the CPNP only applies to cosmetic products. If the product is wrongly classified, the notification will not solve the issue. It will simply document it more efficiently.
Step 3. Review the label before notification
Another essential step before notification is checking that the label complies with Article 19 of Regulation 1223/2009. The SHAPYPRO presentation lists the main required elements: Responsible Person and country of origin, nominal content, expiry date or PAO, precautions and warnings, batch number, product function, and ingredients, together with the language requirements applicable in the country of sale.
This matters because the information notified in the CPNP must be consistent with the actual product. The name, function, presentation and regulatory data must all match the final label and the technical dossier.
Step 4. Prepare the technical documentation: PIF and CPSR
A CPNP registration cannot realistically be handled properly without first preparing the PIF and the CPSR. According to the presentation, the Product Information File should include at least the product description, the Cosmetic Product Safety Report, the manufacturing method, proof of GMP compliance, efficacy support when claims are made, and the animal testing statement.
The same presentation also explains the structure of the CPSR, distinguishing between Part A, which contains the product safety information, and Part B, which contains the actual safety assessment. Part A includes aspects such as qualitative and quantitative composition, physico-chemical characteristics and stability, microbiological quality, impurities, packaging, reasonably foreseeable use, exposure assessment, toxicological profile, and undesirable effects. Part B includes the assessment conclusion, label warnings and instructions for use, reasoning, and the credentials of the safety assessor.
In other words, the CPNP does not replace the dossier. The CPNP comes after the dossier.
Step 5. Complete the notification in the CPNP
Once the previous elements are in place, the notification can be made in the portal. The SHAPYPRO presentation describes it as the “final gateway” to access the EU market and emphasises that it is the mandatory electronic system for product notification. It also notes that the process is relatively straightforward once all the required information has been properly prepared.
At a practical level, the logic of CPNP registration is to enter the key product data electronically before placing the product on the market. From a regulatory point of view, the important thing is that the notification is made only when the product is already properly supported by its classification, labelling and technical documentation.
Step 6. Consider additional requirements if the product contains nanomaterials
This is one of those details that look minor until they become a real problem. If a formula contains nanomaterials, additional notification requirements may apply. For that reason, if a product includes ingredients that could fall into this category, this point should be reviewed before the launch timeline is finalised.
What information should be ready before entering the portal?
Although the CPNP is the notification step, it works best when everything has already been organised properly. Before entering the system, it is advisable to have at least the following ready:
- the Responsible Person in the EU;
- the correct classification of the product as a cosmetic;
- compliant labelling;
- the complete PIF;
- the final signed CPSR;
- and, where relevant, the analytical and testing support for the product.
The SHAPYPRO presentation also includes analytical and testing requirements as the final block of the process, highlighting the importance of organoleptic and physico-chemical analyses, microbiology, challenge testing, stability, compatibility, and, where relevant, tolerance or efficacy testing.
How SHAPYPRO can help
In this process, SHAPYPRO can help structure CPNP registration as part of a complete regulatory strategy. That includes reviewing whether the product is correctly classified, checking the label, preparing or reviewing the technical documentation, coordinating the CPSR, and verifying that the information to be notified in the portal is consistent with the actual product. And yes, that basic consistency, which should be obvious, is exactly where many projects start to wobble.
Conclusion
Registering a product in the CPNP is not simply a matter of completing an online form. It is the result of having handled several earlier steps correctly: appointing a Responsible Person, confirming that the product is a cosmetic, reviewing the label, preparing the PIF and CPSR, and checking whether any additional requirements apply, such as those related to nanomaterials. The notification itself is mandatory and centralised, but it only works properly when all the earlier regulatory work is already in order.
For a brand, manufacturer or importer, understanding this helps save time and reduce mistakes. Because in cosmetic regulation, what looks like a simple “final step” usually depends on having solved the previous five properly.