I notified my own products within the CPNP
First introduced in January 2012, the Cosmetics Products Notification Portal (CPNP) is a European notification platform intended for submitting technical compliance related information regarding cosmetic products to conveniently convey to any relevant competent authorities that a cosmetic product is fully compliant with all concerned directives and regulations. Created under Regulation 1223/2009/EC, the CPNP aims at harmonizing cosmetics products within all EU Member States (including four EFTA countries) covered by the legislation. The regulation also makes CPNP notification a mandatory part of the compliance process for all cosmetic products seeking to enter the European Market.
One important aspect of regulation 1223/2009/EC to note relates to just who is allowed to submit a product to the CPNP. It states that all products, in order for the notification to be valid, must be submitted by an officially appointed European Responsible Person – especially in the case of manufacturers based outside of the European Union. This requirement would, of course, imply that, in such cases, self-notification to the CPNP cannot work.
Access to the CPNP is open to the general public for notification purposes and also for greater transparency. As a result of this, it can be the case that the notification process can be carried out by anyone. However, this can lead to many misunderstandings as a product’s being notified does not necessarily mean that it is compliant. It is a common misconception that just because someone can access the CPNP and complete the notification process that the notification is valid. This is not the case. Notification can only be carried out by a Responsible Person with a valid EU login.
Unfortunately, it can often be the case that a distributor offers CPNP notification services to a manufacturer or brand owner as part of their distribution package. Cases where the distributor does not take on the role of the Responsible Person (see this recent article on why appointing a distributor as RP can be a bad idea) can do far more damage than good as they usually result in the product needing to be re-notified.
In summation, in an effort to complete the process as correctly and efficiently as possible, it is highly inadvisable for manufacturers or brand owners to engage in self-notification to the CPNP and instead take the official route of having their Responsible Person complete the process.
For more information on the cosmetic product notification process, to receive a free quote on our European Responsible Person Services, or to find out how Obelis’ team of regulatory and notification experts can help your project enter the European Market, contact us today.