CPNP Notification as Distributor – What Cosmetic Brands Must Know in 2026
Entering the European cosmetics market requires more than product excellence. It requires regulatory precision and strategic compliance planning.
Under EU Regulation (EC) No. 1223/2009, cosmetic products must be notified in the Cosmetic Product Notification Portal (CPNP) before being placed on the EU market. However, one critical aspect is often overlooked: in certain situations, distributors may also be subject to notification obligations.
This guide explains when CPNP notification as distributor is required and how to structure compliance correctly and efficiently
What Is the CPNP and Why Does It Matter?
The Cosmetic Product Notification Portal (CPNP) is the official EU platform that provides competent authorities with immediate access to essential product information.
This system ensures product traceability, consumer protection, and regulatory transparency across the European Union. Consequently, notification must be completed before a cosmetic product is placed on the EU market for the first time.
Proper CPNP handling is therefore not just a legal requirement — it is a market entry prerequisite.
When Is a Distributor Required to Submit a CPNP Notification?
A distributor is not automatically obliged to notify a product. However, specific actions may trigger additional regulatory responsibilities.
CPNP notification as distributor is typically required when:
The product is imported from a non-EU country
The labeling is modified
The product is marketed under the distributor’s own brand
The product is introduced into an additional EU Member State
Therefore, a careful regulatory role assessment before market entry is essential.
Distributor vs Responsible Person – A Common Misconception
It is often assumed that only the Responsible Person is responsible for CPNP notification. While this is generally correct, the situation changes if the distributor modifies the product or acts as importer from a third country.
In such cases, additional obligations may arise under EU law.
A clear distinction must always be made between:
Responsible Person obligations
Distributor-level notification obligations
A structured compliance strategy significantly reduces regulatory risk and prevents costly delays.
Practical Challenges in Distributor-Level Notification
In practice, common compliance issues include:
Incorrect product category classification
Incomplete or inconsistent ingredient documentation
Misalignment between product labeling and CPNP data
Insufficient coordination with the Responsible Person
An incorrect or incomplete notification may result in market delays, regulatory exposure, or liability risks.
Conclusion
CPNP notification as distributor is not required in every scenario. However, when triggered, it must be handled professionally and in full compliance with EU legislation.
Clear role allocation, accurate documentation, and structured submission ensure a secure and compliant entry into the European cosmetics market.