‍A guide to submitting cosmetic product notifications through the CPNP and SCPN portals, including what documentation you need, how the UK and EU systems differ, and where beauty brands most commonly run into delays.

Every cosmetic product sold in the UK or EU must be formally notified to the relevant authority before it reaches a consumer. The process is sometimes referred to as cosmetic product registration, though technically it's a notification rather than a registration or approval. It applies whether you're a multinational with hundreds of SKUs or an indie brand launching your first serum.

For beauty brands entering either market, it's one of the most common points at which product launch timelines stall. While the notification itself is an online submission, it depends on having a lot of other documentation ready first. If those building blocks aren't in place, the submission can't go ahead, and neither can your launch.

This guide walks through how cosmetic product notification works in both the UK and EU, what you need to prepare before you submit, and where delays and errors tend to crop up.

‍Two markets, two portals

Since Brexit, the UK and EU operate entirely separate notification systems. A notification in one does not count in the other, and there's no data transfer between them.

For the EU, the system is the Cosmetic Products Notification Portal (CPNP), managed by the European Commission under the EU Cosmetics Regulation (EC 1223/2009). A single CPNP notification covers all 27 EU Member States plus the EEA countries (Norway, Iceland and Liechtenstein). You notify the Commission once and you're covered across the whole bloc — there's no need for additional national-level notifications.

For the UK, the system is the Submit Cosmetic Product Notifications (SCPN) service, overseen by the Office for Product Safety and Standards (OPSS). This covers Great Britain (England, Scotland and Wales) under the UK Cosmetics Regulation, which retained the EU framework with independent UK oversight after Brexit.

For brands working out how to sell cosmetics in the UK and EU, you'll need to complete both notifications separately.

‍A note on Northern Ireland

Northern Ireland follows EU rules under the Windsor Framework. That means cosmetic products placed on the market here must be notified through the CPNP, not the SCPN. 

If you're distributing across the whole of the UK and the EU, you may need notifications in both portals, with the Northern Ireland portion sitting under the EU system. It's a detail that catches many cosmetic brands off guard, particularly those assuming a single UK notification covers the entire United Kingdom.

It's also worth noting that cosmetic products placed on the Northern Ireland market under EU rules can be sold in the rest of the UK without additional approvals. However, Northern Ireland-based Responsible Persons must still notify the GB regulator via SCPN with the product's ingredient details.

‍Who can submit a notification?

In both jurisdictions, only the designated Responsible Person can submit the notification.

Read more on choosing a Responsible Person for your cosmetics brand. 

For the EU, the Responsible Person must be established within the EU. This can be the manufacturer (if they're EU-based), the importer, the distributor (if they're placing the product on the market under their own name or trademark, or modifying it in a way that could affect compliance), or a third party appointed by your brand through a written mandate.

For the UK, the Responsible Person must be established in the UK. The same categories apply — manufacturer, importer, distributor (if they're labelling the product under their own brand), or an appointed representative. 

Importantly, your EU Responsible Person and your UK Responsible Person cannot be the same entity unless that entity is established in both jurisdictions. 

‍What you need before you can notify

Many brands underestimate the work involved in submitting a cosmetic product notification. The notification itself is an online form, but the information it asks for only exists if you've already completed several upstream steps. You can't fill in a CPNP or SCPN notification with marketing copy and good intentions; it requires specific regulatory data.

Here's what both portals typically require:

‍Product information

The product's category (e.g. skincare, hair care, oral hygiene), its name, physical form, and packaging type. The portals use defined categories, so selecting the wrong one creates issues further down the line. 

‍Responsible Person details

The name and address of your Responsible Person in the relevant jurisdiction, plus contact details for a named individual who can respond to urgent enquiries. In the UK, this contact needs to be available for the National Poisons Information Service and Trading Standards. In the EU, the information feeds through to poison centres across Member States.

‍Product formulation

Both portals require details of what's in the product. The EU system asks for the product's qualitative and quantitative composition, along with a frame formulation (a simplified version using concentration ranges), which is provided specifically so poison centres can deliver appropriate medical treatment.  The UK system similarly requires a summary of ingredients with their chemical details.

This is one of the biggest preparation hurdles for brands. Your formulation data needs to be accurate, complete, and consistent with what's in your Product Information File (PIF) and your Cosmetic Product Safety Report (CPSR). If there are discrepancies between documents — e.g. different ingredient names, mismatched concentrations, outdated versions — you'll run into problems.

‍Nanomaterials

If your product contains nanomaterials, both portals require specific disclosure. In the EU, products containing nanomaterials also need an additional notification under Article 16 of the Cosmetics Regulation, which must be submitted at least six months before the product goes to market. This separate notification asks for the nanomaterial's identification, specifications, estimated annual quantity, toxicological profile, and expected exposure conditions.

While the UK system also requires nanomaterial details, the process is folded into the main SCPN notification rather than a separate submission.

‍CMR substances

Any substances classified as carcinogenic, mutagenic, or toxic for reproduction (CMR) must be declared, with their name and CAS or EC number.

‍Label images and product photos

Both portals ask for an image of the product label and a photograph of the packaging. These need to be legible and current. If your label doesn't match the formulation or Responsible Person details in the notification, that's a compliance issue.

‍The Product Information File comes first

There’s a common misconception that notification is the first step towards beauty product compliance. In reality,  it's closer to the last step in a sequence that begins much earlier.

Before you can notify, you need a complete Product Information File (PIF). The PIF is the comprehensive dossier for each product, containing the formulation details, the Cosmetic Product Safety Report, evidence of GMP compliance, proof to support any claims you're making, and your labelling. The PIF is what your Responsible Person draws on to complete the notification.

Within the PIF, the Cosmetic Product Safety Report (CPSR) is typically the most time-consuming component. It requires a qualified safety assessor to evaluate the product's toxicological profile, ingredient safety, stability, and microbiological quality. Until the CPSR is signed off, the PIF isn't complete, and without a complete PIF, notification can't happen.

‍What are the most common cosmetic notification mistakes?

Having supported many beauty brands through the notification process, we see the same issues come up repeatedly. Most of them are avoidable with the right preparation.

‍Incomplete or inconsistent formulation data

The most frequent source of delay is formulation data that doesn't match across documents. For example, the ingredient list on your label says one thing, but the formulation sheet from your manufacturer says another, and the version in the safety assessment references a third. Before submitting any notification, make sure your formulation data is reconciled across every document that references it.‍

Missing supplier documentation

Safety assessors need data on raw materials, including certificates of analysis, allergen declarations, and specifications sheets. If your supply chain involves multiple ingredient suppliers, gathering consistent documentation from all of them takes longer than most brands expect. Starting this process early, well before you're ready to notify, can save weeks.

‍Label errors

The label image you upload to the portal needs to match the regulatory requirements for the relevant market. That means the correct Responsible Person name and address, ingredients listed in INCI nomenclature and in descending order of concentration, appropriate warnings, and — for EU products — text in the language(s) of the Member State(s) where the product will be sold. 

‍Nanomaterial disclosure gaps

Brands don't always realise that certain ingredients in their formulations are classified as nanomaterials at the concentrations used. Titanium dioxide and zinc oxide in sunscreens are common examples. Failing to declare nanomaterials when they're present is a compliance failure, and in the EU, missing the six-month advance notification window for nanomaterials under Article 16 can delay your launch significantly.

Trying to notify before the PIF is ready

Some brands attempt to submit their notification before the safety assessment is complete, hoping to run the processes in parallel. The notification portals won't accept incomplete data, and submitting inaccurate information to speed things up creates a bigger problem than a delayed launch — it creates a compliance liability that affects your Responsible Person.

‍“We see this a lot with cosmetic brands that are growing quickly. They've got the product ready, the packaging designed, the launch date set, and then they discover the safety assessment isn't finished or their formulation data doesn't match across documents. By the time they reach the notification stage, the delay has already happened further back in the process. That's why we always encourage beauty brands to start the compliance work early, well before they're thinking about portal submissions.”

- Dave Hoogakker, Director, Hooley Brown 

‍What happens after you notify

In both the EU and UK, the notification process is a submission, not an approval. Once you've submitted a valid notification in the CPNP, your product receives a reference number. In the SCPN, you'll receive a notification number and a PDF summary of the submitted details.

From that point, the product can legally be placed on the market in the relevant jurisdiction. However, authorities can (and do) request documentation, carry out market surveillance checks, and investigate complaints. Your PIF needs to remain accessible and up to date for as long as the product is on the market, and for ten years after the last batch is placed on the market.

If anything about the product changes — such as a reformulation, new packaging, or updated Responsible Person details — the notification must be updated promptly. Failing to keep notifications current is one of the most common compliance issues regulators find during inspections.

‍Selling cosmetics in the EU and UK? Plan for dual compliance early

For brands selling in both the UK and EU, the dual notification requirement adds a layer of coordination. You'll need Responsible Persons in both jurisdictions, and while the underlying product data is largely the same, each notification must reference the correct local representative and comply with the specific requirements of each portal.

The most efficient approach is to maintain a single, well-structured PIF that serves both markets, with clearly separated sections for UK and EU Responsible Person details and any market-specific labelling requirements. This avoids duplicating work while keeping each notification accurate and independently compliant.

Brands that treat the UK and EU as one compliance workstream — assuming that satisfying one automatically covers the other — run into delays when they discover, often late in the process, that separate submissions and documentation are required.

‍How Hooley Brown can help with cosmetics compliance

At Hooley Brown, we work with beauty and personal care brands at every stage, from first-time market entry to scaling across multiple jurisdictions. Cosmetic product notification is one piece of a much larger compliance picture, and we help brands get it right from the outset rather than unpicking problems later.

Our support services include acting as the Responsible Persons in the UK and EU, reviewing and preparing Product Information Files, coordinating safety assessments and CPSR sign-off, managing CPNP and SCPN submissions, auditing existing notifications for accuracy and completeness, and advising on the labelling and documentation requirements that underpin a compliant notification.

If you're preparing to sell cosmetics in the UK, the EU, or both regions, and you want to make sure the notification process doesn't hold up your launch, we'd welcome a conversation. 

Whether you need support with CPNP notification, SCPN submission, or preparing your Product Information File, get in touch with our team to discuss your needs.