EU Cosmetics Notified: Ready to Sell Across 27 Markets

EU Regulation 1223/2009 on cosmetic products applies uniformly across all 27 EU member states, including Germany, France, Italy, Spain, and every other EU market. Any cosmetic product placed on the EU market must be notified in the CPNP system before the product is made available to consumers. The notification requirement applies to every cosmetic product regardless of its country of manufacture - brands based in the US, UK, Asia, or any non-EU country must appoint an EU-based Responsible Person to fulfill the notification obligation on their behalf. Germany is one of the largest cosmetics markets in the EU and a common entry point for international brands. Our CPNP service covers notification for the entire EU market through a single engagement, enabling brands to sell across all 27 member states without separate notifications per country.

EU Regulation 1223/2009 requires every cosmetic product to have a named Responsible Person established within the European Union. The Responsible Person bears full legal accountability for the product's compliance with EU cosmetics law - including the safety assessment, notification, labeling, product information file maintenance, and post-market surveillance. For non-EU brands, fulfilling this obligation requires either establishing a legal entity within the EU or appointing an EU-based Responsible Person service. We provide Responsible Person services for cosmetics brands entering the EU market. Our German-registered entity assumes the Responsible Person designation for your product portfolio, maintaining the legal compliance obligations associated with this role while enabling your business to sell across all EU member states. Our service covers the full scope of Responsible Person obligations: maintaining product information files, ensuring CPNP notifications are current, responding to competent authority inquiries, and managing product safety communications when safety signals emerge.

The CPNP portal requires specific product data elements for each cosmetic product notification. Required data includes the product name in each relevant EU language, product function category, frame formulation or full ingredient list in INCI nomenclature, nanomaterial declaration where applicable, and the Responsible Person's contact details. Our CPNP submission team prepares notifications from your product formulation data, ensuring ingredient names are expressed in correct INCI format and product categories are accurately assigned. We submit notifications before products are made available to EU consumers - notification before first placement is a legal requirement, not a best-effort target. For brands already selling in the EU without CPNP notifications in place, we prioritize submissions and implement corrective procedures to close the non-compliance gap as quickly as possible.

EU cosmetics labels must include the product name and function, full ingredient list in INCI order, net content, special precautions, batch reference, minimum durability date or period after opening, and the Responsible Person's name and EU address. For products sold in Germany, labels must include German-language warnings and usage instructions for products in applicable categories. Post-Brexit, products sold in the UK cannot use an EU address. A separate UK Responsible Person address is required. We conduct label compliance reviews for every product before EU launch, checking all mandatory elements against current EU Cosmetics Regulation requirements and German-specific market requirements. We also monitor SCCS (Scientific Committee on Consumer Safety) opinions and regulatory amendments that affect permitted ingredient lists, concentration limits, and labeling requirements.