CPNP Notification for Fragrance Products: A Step-by-Step Guide

Before any cosmetic fragrance product can be legally sold in the European Union, it must be notified on the Cosmetic Products Notification Portal (CPNP), the free online system operated by the European Commission under Article 13 of Regulation (EC) No 1223/2009. The notification is free, but the data behind it is not, and mistakes can delay a launch by weeks.

This guide walks through the process from the perspective of a brand importing fragrance from China.

What CPNP Is and Is Not

CPNP is a notification system, not an approval system. The Commission does not review or authorize your product. Submitting a notification does not mean the product is compliant; it means the relevant authorities have been informed and can request the Product Information File (PIF) at any time.

The notification is valid across all EU member states plus Iceland, Liechtenstein, and Norway. The UK operates a separate system, the Submit Cosmetic Product Notification (SCPN) service, since Brexit. Northern Ireland still uses CPNP under the Windsor Framework.

CPNP applies only to cosmetic products. Candles, reed diffusers, and room sprays are not notified on CPNP; hazardous mixtures among them are notified separately to poison centers via the PCN portal under Annex VIII of CLP.

Who Submits

The Responsible Person (RP) submits the notification, or a distributor who modifies a product (for example, by relabeling) and thereby becomes the RP for that product. A non-EU brand cannot submit directly; it must work through its appointed EU RP.

Step 1: Prepare the Required Data

Before logging in, gather:

• RP details: legal name, EU address, country, contact person, email, phone.
• Product identification: trade name, internal reference, product function from the EU framework list (for fine fragrance, “perfuming”).
• Frame formulation: either an exact quantitative formula or a frame formulation selected from the Commission’s published list. Most fragrance products use a frame formulation such as “ethanol-water-fragrance” with concentration ranges.
• Full ingredient list with INCI names and CAS numbers, including the 26 fragrance allergens (expanding to 80+ under Regulation (EU) 2023/1545) when present above 0.001% in leave-on or 0.01% in rinse-off products.
• CMR substances: any ingredient classified as Carcinogenic, Mutagenic, or Reprotoxic, with justification of compliance with Article 15.
• Nanomaterials: notification at least six months before placing on the market, with the data set out in Article 16.
• Original label and a photograph of the packaging, legible enough for authorities to verify Article 19 compliance.
• CPSR confirmation: the notification asks for confirmation that a Cosmetic Product Safety Report exists and is held by the RP.

Step 2: Create an EU Login Account

The RP registers an EU Login account at ec.europa.eu and links it to a CPNP profile. The profile includes the organization’s legal name, address, and the role (RP, distributor, or national authority). Account verification can take a few business days, so do this before your launch deadline.

Step 3: Enter the Notification

Inside CPNP, the RP creates a new notification and completes the screens:

1. Responsible Person details, pre-filled from the profile.
2. Product identification: name, reference, country of first placement, and product category.
3. Frame formulation: select the framework and enter the concentration ranges of the major blocks (ethanol, water, fragrance compound, colorants, preservatives).
4. Ingredients: enter each ingredient with INCI name, CAS number, and concentration or range. Flag CMRs and nanomaterials.
5. Labeling: upload the label artwork and a packaging photograph.
6. CPSR confirmation: confirm the report exists, name the safety assessor, and confirm the report is held at the RP address.
7. Submission: review and submit. The system generates a CPNP reference number immediately.

There is no fee and no waiting period for standard products. The product can be placed on the market from the moment of submission, provided the PIF is complete.

Step 4: Maintain the Notification

The notification must be updated whenever:

• The formula changes, even slightly.
• The RP changes (a new RP must take over the notification before the old one steps down).
• The label changes in a way that affects Article 19 fields.
• The product is withdrawn or recalled.

Failure to update is itself a violation. Authorities cross-check CPNP data against the PIF during inspections, and inconsistencies trigger follow-up.

Common Rejection and Inspection Issues

• Missing allergens. The notification must list every allergen above the threshold; a generic “parfum” entry is not enough at the ingredient level.
• Frame formulation mismatch. The selected framework must match the actual composition. A reed diffuser base mistakenly entered under a perfume framework will fail review.
• Label without RP address. The label uploaded must show the RP’s EU name and address.
• No CPSR behind the notification. Authorities can request the CPSR within 72 hours; if it does not exist, the product is non-compliant from day one.
• Outdated allergen list. Regulation (EU) 2023/1545 expanded the allergen list with a transition period ending July 2026 for new products and July 2028 for existing stock. Notifications should reflect the current list as it applies to your timeline.

Step 5: Don’t Forget Adjacent Obligations

CPNP notification is one of several EU obligations for cosmetic fragrance:

• PIF and CPSR held for 10 years after the last batch is placed on the market.
• GMP per EN ISO 22716.
• Serious undesirable effect reporting under Article 23.
• Poison center notification (PCN) if the product is also classified as hazardous under CLP, which applies to many alcohol-based perfumes.

How Aromiso Helps

Aromiso provides the upstream data CPNP requires: full INCI ingredient lists with CAS numbers, allergen declarations, IFRA certificates, CMR statements, and the technical dossier a safety assessor needs to write the CPSR. We coordinate directly with our buyers’ RPs so the CPNP notification can be submitted as soon as the first production batch is confirmed.

If you are preparing your first EU launch, ask us for our CPNP data package checklist. It maps every CPNP field to the document we deliver, which typically cuts the notification preparation time in half.