In different international markets the safety, quality, efficacy, and labeling of cosmetic products have different requirements, and in some of them it is mandatory to make a notification to the competent authorities. As an example the following countries follow this obligation:
Europe
United Kingdom
Switzerland
Japan
China
Canada
MERCOSUR and CAN Markets
ASEAN Markets
When we talk about CPNP, we talk about the portal created by the European Commission for the notification of cosmetic products called Cosmetics Products Notification Portal.
It is a portal that allows a centralized notification system at European Union level, according to Regulation (EC) No 1223/2009 on cosmetic products, thus avoiding that any further notification has to be made at national level, with each member country of the European Union.
Mandatory since July 11, 2013, all cosmetic products must be notified at CPNP before being placed on the market. However, it is important to understand that the notification of a cosmetic product is only one step within several that must be taken to comply with all applicable legislation.
The CPNP portal, aims to be a single point for making information available to the following authorities:
Competent authorities (for market analysis, market surveillance and consumer information);
European Poison Control Centers (for medical treatment);
Cosmetic Products Responsible (when notifying cosmetics);
Cosmetic products distributors (when notifying cosmetics products).
The CPNP is not publicly accessible. However, the name and address of the person or company on whom the notification is made (Responsible Person) must be printed on cosmetic product labels. This is mandatory so that end consumers know who to contact if they experience any unusual reactions and how best to proceed.
This procedure is usually called notification, although in some countries it may be called registration, due to differences in legislation.
What happens if my product has nanomaterials?
Cosmetic products containing nanomaterials must be notified at least six months before being placed on EU markets.
The CPNP includes a separate module (Article 16) allowing the inclusion of cosmetic products containing nanomaterials. This notification must be submitted in addition to Article 13.
The European Commission may ask the Scientific Committee for Consumer Safety to carry out a risk assessment if it has concerns about the safety of nanomaterials.
Important information to reinforce is that the CPNP is only the final step in a very complex regulatory process. The first three mandatory steps are formula review, CPSR (cosmetic product safety report), A and B signed as Toxicologist, and label and claims review.
Who is responsible for the notification of my products?
Notification (or registration) cannot be done in all countries by the same person or company, as it depends on each country's cosmetic regulations.
In certain countries, the importer or distributor may be automatically responsible. However, in some cases, it may be the brand that takes responsibility.
Usually, the Responsible Person in the EU handles the notification in the CPNP. Article 13 of Regulation (EC) No 1223/2009 defines that the Responsible Person (or distributors of cosmetic products) must provide information through CPNP about the products they place on European markets.
In the EU, this is a very important and sensitive challenge, and so it is very important to be very careful when choosing anyone to be your Responsible Person, and here is why:
The Responsible Person will have access to a lot of confidential information about your products;
A Responsible Person must have strong knowledge in regulatory affairs, pharmaceutical sciences, toxicology and chemistry;
To manage interactions with customers and with the 27 National Competent Authorities (in 24 languages), the Responsible Person must have strong communication skills.
The Responsible Person must fulfill various tasks that require a great deal of knowledge and time.
What are the impacts of Brexit?
Also, it is important to remember that although the EU and UK Cosmetics Regulations are almost identical, there are some changes due to Brexit.
First, and most importantly, the notification is not submitted to the same portal. In the EU it is submitted on CPNP, while in the UK it is submitted via SCPN (Submit Cosmetic Product Notifications);
A second important point that many people do not know is that a notification in the EU's CPNP can be transferred to another Responsible Person (for different reasons leading to the need to change the Responsible Person), whereas for a notification in the UK's SCPN the same does not apply, which requires, in case of change of Responsible Person, a new notification.
Pharmilab will be happy to assist you if you need someone to handle your CPNP (Cosmetic Product Notification Portal) notifications in the EU or SCPN (Submit Cosmetic Product Notification) notifications in the UK.