CPNP Notification for Baby Care: What Information Is Required and Who Files It

In the EU, baby care products such as lotions, shampoos, wipes, and sunscreens must undergo Cosmetic Product Notification Portal (CPNP) submission before being placed on the market. For sourcing managers and brand owners, understanding what information your supplier should provide — and who must file — is essential to keep your launch on time and compliant.

Who Files the CPNP Notification

Under EU Regulation (EC) No 1223/2009, the CPNP notification must be filed by the “Responsible Person” (RP) established within the EU. This can be:

• Your own EU legal entity, if you take on RP duties.
• An appointed third-party Responsible Person service provider.
• Your manufacturer or distributor, if they agree to and are legally able to act as RP.

Note: The RP assumes responsibility for the product’s compliance, safety assessment, and accurate notification to CPNP.

Information Required for CPNP Notification

For baby care products, the required data is both technical and regulatory. Ensure your supplier delivers:

• Product Category & Intended Use – Specific for baby/infant demographic.
• Product Name and Variants – Matching ALL labels exactly.
• Responsible Person details – Name, address, and contact info within EU.
• Member State of First Placement – Country where product enters EU market.
• Ingredients list – INCI names with exact percentages (ranges possible for fragrance).
• Nanomaterial declaration – Where applicable, with justification files.
• Label artwork – All in-market languages covering mandatory warnings, instructions.
• Safety Report – Cosmetic Product Safety Report (CPSR) signed by a qualified safety assessor.
• Packaging description – Type, material, and capacity.
• Photo of product packaging – Finished retail presentation.

Buyer Action Plan

1. Confirm with supplier who will act as RP and manage CPNP filing.
2. Request the full evidence pack early (ingredients, CPSR, label files, photos).
3. Lock EU-compliant labels before pilot production.
4. Schedule CPSR review to avoid delays in notification.

Sample CPNP Evidence Table

FAQs

Do baby sunscreens need extra information?

Yes. For SPF products, you must include photostability testing data and UVA/UVB performance metrics in the CPSR and CPNP submission.

Can a non-EU company file directly?

No. Only an RP established within the EU can file. Non-EU companies must appoint an RP or work with a compliant partner.

How long does CPNP notification take?

Once all evidence is ready, submission is typically completed in 1–5 business days. Delays occur if documents are incomplete or misaligned with labels.

Is CPNP approval or certification?

CPNP is a notification process, not a pre-market approval. The portal registers products so authorities can access key compliance data.

Final Steps

To avoid launch delays, lock your responsible person choice and evidence pack before finalizing production. Align all stakeholders — manufacturer, safety assessor, label designer — to the EU compliance timeline.

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Hi, I'm Alex Zong, hope you like this blog post.

With more than 20 years of experience in OEM/ODM/Private Label Cosmetics, I'd love to share valuable knowledge related to cosmetics & skincare products from a top-tier Chinese supplier's perspective.