Cosmetics into the EU: The CPNP Notification Nobody Told You About
Introduction
Picture a container of face serums, sheet masks and lip balms leaving Yantian on schedule. The commercial invoice is clean, the packing list matches the cartons, the HS codes have been checked twice and the freight is paid. Then the goods reach Rotterdam, and the EU importer’s compliance team asks a single question that nobody in the chain can answer: what is the CPNP reference for each product? The factory assumed the brand owner had handled it. The brand owner assumed the importer had. The forwarder had never heard the term. Meanwhile the cartons sit in a terminal yard and the storage charges begin to add up.
This is not a rare story, and 2026 has made it more expensive. In a coordinated customs operation that ran from October to December 2025, customs authorities in all 27 Member States checked close to 6,000 cosmetic items bought online from outside the EU, and about 65 percent failed to comply, according to the European Commission. A wider Commission report published in July 2026 found that more than 60 percent of the toys, small electronics, cosmetics, protective equipment and food supplements checked in that exercise missed EU product requirements. Since 1 July 2026 the EU has also charged a flat €3 duty on low-value parcels, with item-level product identifiers and a handling fee scheduled to follow. The direction of travel is obvious: more data, more scrutiny and less patience for cargo that arrives without a compliance file.
This guide is written for freight forwarders, cross-border sellers and cosmetics exporters who ship from China to Europe. It explains what the Cosmetic Products Notification Portal (CPNP) really is, who is legally responsible for it, what changed this year, and how to build a shipping workflow in which the paperwork is finished before the cargo moves. Along the way we show where a logistics partner such as Topway Shipping fits into the picture, and where it does not.
What the CPNP Is, and What It Is Not
A notification, not an approval
The CPNP is a free online system run by the European Commission under Regulation (EC) No 1223/2009, the EU Cosmetics Regulation. Before a cosmetic product is placed on the EU market, its Responsible Person must submit a defined set of information about it to the portal. One notification covers the whole EU market, so no separate filings are needed in individual Member States. The data is also used by market surveillance authorities and poison centers, which is why accuracy matters more than speed.
The word that matters is notification. Nobody at the Commission reviews your product, tests it or approves it, and the reference number is issued the moment the submission is complete. That makes the CPNP quick to use, but it also means the number proves only that someone filed something. It does not prove that the product is safe or legal. Regulators understand this perfectly well, which is why they treat a CPNP entry as the starting point of an inspection rather than the end of it.
What actually goes into the notification
Article 13 of the Regulation sets out the core data. The Responsible Person must supply the product category and a name that identifies it specifically, the name and address of the Responsible Person where the Product Information File is kept, the country of origin for imported goods, the Member State where the product will first be placed on the market, and a contact person who can be reached in an emergency. The notification must also state whether nanomaterials are present, name any substances classified as carcinogenic, mutagenic or toxic to reproduction in categories 1A or 1B, and provide a frame formulation that lets a poison center respond quickly if a consumer is harmed. In practice the portal also asks for images of the original label and packaging.
Nanomaterials have a track of their own. Products that contain them need an additional notification under Article 16, and the Commission can ask its scientific committee to assess a nanomaterial if it has safety concerns. For exporters of mineral sunscreens or certain color cosmetics this is not an academic point, because a missing nano declaration gives an authority a clean reason to challenge the product.
Table 1 summarizes the main data blocks and the mistakes we see most often on cargo coming out of Asia.
Table 1. Main data blocks in a CPNP notification and the errors that cause trouble
| Data element | What it covers | Frequent mistake |
| Category and name | Product type and the exact trade name shown on the pack | The name in the portal differs from the name printed on the label |
| Responsible Person | EU-established name and address where the PIF is kept | Naming the factory, a UK entity or a forwarder that never agreed to the role |
| Country of origin | Where the finished product was made, for imported goods | Omitting it, or showing a different origin on the customs invoice |
| Member State of first placement | The EU country where the product is first placed on the market | Guessing the field instead of confirming which entity is importing |
| Nanomaterials and CMR substances | Declaration of nano ingredients and CMR 1A/1B substances | Assuming a raw material is nano-free without a supplier declaration |
| Frame formulation | Ingredient ranges used by poison centers in emergencies | Pasting in a generic formula that does not match the real product |
| Label and packaging images | The original label as it will appear on the market | Uploading draft artwork that changes before production |
The reference number is easy to get and easy to misread
Because the notification is instant, it is tempting to treat the number as a certificate, and suppliers often encourage that impression. It is common to receive a CPNP number in a supplier’s email signature that belongs to a different product, or to a Responsible Person who has never seen the current formula. The check we recommend is simple. Ask who the Responsible Person is, ask to see the notification record, and confirm that the product name and label images match what is actually in the carton. If a supplier claims to have a number but will not name the Responsible Person, treat that as a warning sign rather than a formality.
Filings made for other markets do not carry over either. A US FDA facility listing, a Chinese NMPA record or a UK SCPN notification has no legal weight in the EU. Great Britain runs its own portal and requires its own Responsible Person, and a Responsible Person based in Britain does not satisfy the EU requirement after Brexit.
Why This Suddenly Lands on the Freight Desk
What the 2025 customs sweep revealed
The second phase of the Commission’s priority control area ran from October to December 2025. Customs authorities in 27 Member States, working with market surveillance and food safety colleagues, pulled cosmetics, personal protective equipment and food supplements out of e-commerce flows and examined 11,338 pieces in total. For cosmetics and protective equipment, controls concentrated on the four largest marketplaces, which together account for more than 90 percent of low-value consignments entering the EU. Close to 6,000 cosmetic items were checked, and roughly 65 percent did not comply.
There is a caveat that some shippers latch onto. The Commission’s July 2026 report notes that in 2025 only about 65 items per million imported were controlled and fewer than 10 per million were refused at the border. Anyone reading that as a reason to relax is reading last year’s story. The same report points to a new EU Customs Authority in Lille to coordinate risk management and to a central customs data hub that will gradually replace national systems. Sweeps with failure rates like these feed targeting rules, and targeting rules make the next inspection better aimed than the last.
The July 2026 customs reform
On 1 July 2026 the EU ended the €150 duty exemption for low-value consignments. In its place is a temporary flat duty of €3 per item, determined by tariff heading rather than by quantity, on goods valued at €150 or less sold by non-EU sellers registered in the Import One-Stop Shop. Those sellers account for an estimated 93 percent of e-commerce imports, so the measure reaches almost every direct-to-consumer parcel. It is designed to run until a permanent arrangement takes over, expected around 2028 when the EU Customs Data Hub becomes operational.
Two further pieces are in motion. A customs handling fee of roughly €2 per item line is targeted for 1 November 2026, and product identifiers on customs declarations for distance sales, voluntary since 1 July, are scheduled to become mandatory on the same date. The final fee amount and the technical details were still waiting on implementing legislation expected around September 2026, so anyone building a price list should confirm the current position with their customs broker before committing.
Why does a duty reform belong in an article about a cosmetics portal? Because item-level data is what makes compliance visible. When every declaration line carries a specific description and an identifier, a cosmetic product with no Responsible Person and no notification is much easier to spot than it was in a bulk parcel record. Trade press covering the reform expected the beauty and personal care sector to face closer scrutiny for exactly this reason.
Bulk business-to-business shipments to an EU warehouse are not the target of the €3 duty, but they meet the same product-compliance gate. Whether the cargo arrives as a pallet for an Amazon prep center or as a parcel for a shopper in Lyon, the questions about the Responsible Person, the notification and the label are identical.
Marketplaces and retailers check the same number
Customs is only one of several gatekeepers. Amazon’s EU stores ask for the CPNP reference when a cosmetic listing is created, and listings without a valid reference are rejected or suspended. Retail buyers at major beauty chains typically include CPNP verification in their supplier onboarding, and customs authorities in several Member States check notification status on imported cosmetics, especially when the origin is outside the EU. Even if a container clears the port, the commercial gate can still close behind it, and a warehouse that cannot receive the goods against a valid reference turns a compliance gap into a logistics problem.
The Responsible Person: The Role Everyone Assumes Someone Else Has Filled
Every cosmetic product on the EU market needs a Responsible Person established inside the EU. Article 4 of the Regulation is blunt about it: only products with a designated Responsible Person may be placed on the market. This person or company is the legal anchor of the entire system. It ensures compliance with the Regulation, keeps the Product Information File, files the CPNP notification, deals with authorities and takes corrective action or organizes a recall if something goes wrong.
For a product made in China and sold in Europe, the Responsible Person is either the importer or someone the importer appoints in writing. The factory cannot fill the role unless it has an entity established in the EU, and a company in the UK does not count. Non-EU brands usually solve this by engaging a specialist Responsible Person service or by persuading an EU distributor to accept the liability, and either route needs a written mandate.
Only the Responsible Person can submit the notification. That single fact explains many stalled shipments: a supplier cannot hand over a notification it never had the legal standing to make.
How an importer becomes the Responsible Person by accident
Article 4 contains a provision that catches small importers off guard. For an imported cosmetic product, each importer is the Responsible Person for the specific product it places on the market, unless it designates someone else by written mandate and that person accepts in writing. If your consignee is a small EU reseller who bought a few pallets and never appointed anyone, that reseller is the Responsible Person by default, with the safety report, the information file and the notification all landing on its desk. Many discover this at the border rather than before it.
For forwarders the point is delicate. A forwarder or customs representative acting as an agent in the clearance is not automatically an importer. Businesses that take title to the goods, or that act as importer of record in a delivered-duty-paid arrangement, should be very careful about which obligations they attract. Before you sign customs declarations in your own name for a cosmetic product, get written clarity on who the Responsible Person is, and take legal advice if the answer is not obvious. This article is general information and not legal advice.
The safety report and the information file behind the notification
The notification sits on top of two heavier documents. The Cosmetic Product Safety Report, prepared by a qualified safety assessor, has a technical part covering the product’s safety information and an assessment part in which the expert concludes whether the product is safe under normal use. The Product Information File pulls that report together with the product description, the manufacturing method and good manufacturing practice statement, proof of effect where a claim is made, and data on animal testing. It must be kept for ten years after the last batch is placed on the market and be available to authorities at the Responsible Person’s address.
Customs officers rarely open a Product Information File. They tend to check what is visible: the presence of a Responsible Person, a CPNP notification and a compliant label. That does not make the file optional. It has to exist before the product is imported, and its absence is a breach even if nobody notices it at the port. A forwarder cannot audit a safety report, but it can ask the Responsible Person to confirm in writing that the report and file are complete, and it can decline to book cargo when the answer is vague.
Labels: where the paperwork meets the carton
The label is the one part of the compliance file that an inspector can read without a laptop. Under Articles 19 to 21, it must carry the name and address of the Responsible Person, with the address where the information file is available highlighted if several appear, and the country of origin for imported products. It must also show the nominal content unless the pack holds less than five grams or five milliliters, the date of minimum durability or the period-after-opening symbol, the batch number, any required precautions, the function of the product unless obvious, and the ingredient list in INCI nomenclature.
Language is set by each Member State, which means a single label seldom works for the whole EU. Brands either print multilingual labels or apply market-specific stickers, and stickers cause their own problems when they cover mandatory information or peel in humid conditions. If relabeling happens after arrival, make sure the Responsible Person has approved the process, because a product that leaves a warehouse with a non-compliant label is still a non-compliant product.
A simple habit pays for itself. At loading, photograph one carton and one retail unit of each SKU, then compare the label with the images in the CPNP record. Name, Responsible Person address, origin statement and batch format should all match. It takes minutes and catches the errors that authorities and marketplace reviewers look for first.
What Changed in 2026: Rules That Can Make a Notified Product Non-Compliant
A CPNP notification is not a one-time achievement. The rules around it keep moving, and several important changes arrived in the past twelve months. A product that was notified and legal a year ago can become unsellable without any change to the product itself.
Omnibus VII and VIII: no grace period for banned substances
The Commission publishes an annual Omnibus regulation that aligns the Cosmetics Regulation with the latest CMR classifications under the CLP Regulation. Omnibus VII, Regulation (EU) 2025/877, applied its prohibitions from 1 September 2025 and removed substances such as the nail gel photoinitiator TPO from the market. Omnibus VIII, Regulation (EU) 2026/78, was published in January 2026, adds 18 substances to the lists of prohibited or restricted ingredients and applies from 1 May 2026. It also sets particle-size conditions for silver and conditions for hexyl salicylate.
The crucial detail, highlighted by Ireland’s HPRA, is that the Regulation draws no distinction between placing on the market and making available. Products containing affected ingredients became non-compliant on the application date and had to leave the market, with no sell-through period. Omnibus IX is in preparation with an indicated application date of 1 February 2027. For a forwarder, this means cargo produced under an old formula and sitting in a warehouse can become illegal while it waits for a sales order.
Fragrance allergens and label reprints
Regulation (EU) 2023/1545 expands the list of fragrance allergens that must be named on the label by 56 substances. The new rules apply from 31 July 2026 to products newly placed on the market, with a longer runway until 31 July 2028 for products already on the market. Perfumes, scented lotions and hair products are the obvious cases, and every affected label needs new artwork, a new print run and a matching update of the CPNP images.
Packaging rules under the PPWR
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has generally applied since 12 August 2026. From that date every packaging type placed on the EU market needs a manufacturer-issued declaration of conformity backed by technical documentation, and importers are expected to collect and keep those declarations. Cosmetics are directly affected, because jars, tubes, pumps, cartons and gift boxes are all packaging. Brands that put their own name on packaging take on the manufacturer’s obligations, including registration with national extended producer responsibility schemes.
Many of the more visible requirements, such as harmonized material-composition labels and recycled content targets, arrive later between 2028 and 2040. The August 2026 documentation duty, however, is already live. When a retailer, marketplace or importer asks for packaging documents alongside the CPNP reference, that is why.
Microplastics and a regulation under review
Regulation (EU) 2023/2055 restricts intentionally added synthetic polymer microparticles in cosmetics on a staggered timetable: rinse-off products from 17 October 2027, leave-on products from 17 October 2029, and some make-up, lip and nail products later, up to 2035. Separately, the Commission began a full evaluation of the Cosmetics Regulation itself in mid-2025, scheduled to run to mid-2026, so further structural change is possible. Table 2 pulls the main dates together.
Table 2. Key EU dates for cosmetics shipments, 2025 to 2029
| Date | Measure | Why it matters for shipments |
| 1 Sep 2025 | Omnibus VII (Reg. 2025/877) prohibitions apply | Stock containing newly banned CMR substances, such as TPO in nail gels, can no longer be sold |
| Oct to Dec 2025 | Coordinated customs control on e-commerce imports | About 65% of nearly 6,000 checked cosmetic items failed to comply |
| 1 May 2026 | Omnibus VIII (Reg. 2026/78) applies | 18 more substances affected, with no sell-through period according to regulators |
| 1 Jul 2026 | €3 duty per item on low-value B2C imports; voluntary product identifiers | Item-level cost and item-level data for direct-to-consumer parcels |
| 31 Jul 2026 | New fragrance allergen labeling for newly placed products | Label artwork and CPNP images need updating |
| 12 Aug 2026 | PPWR generally applies | Packaging declarations of conformity and producer registration |
| 1 Nov 2026 (targeted) | Mandatory product identifiers; handling fee of about €2 per line | Amount and details pending implementing acts, so confirm before pricing |
| 1 Feb 2027 (indicated) | Omnibus IX | Further CMR-driven bans and restrictions expected |
| 17 Oct 2027 | Microplastics restriction begins for rinse-off products | Reformulation of affected rinse-off ranges |
| 31 Jul 2028 | Fragrance allergen rules reach products already on the market | Full portfolio relabeling |
From Factory to Port: A CPNP-Ready Shipping Workflow
The most reliable way to avoid problems is to treat compliance as a milestone on the shipping timeline rather than a task for later. The sequence below is the one we would want every cosmetics exporter to follow, whether the cargo goes by sea or by air.
Stage one: screen the formula and the claims
Compliance work starts before production. Screen the full ingredient list against Annexes II to VI of the Regulation, because formulas built for other markets routinely contain a handful of ingredients that are restricted or prohibited in the EU. Running that screen early costs little, while discovering the problem after the batch is filled costs the batch. Product claims deserve the same attention. Words such as hypoallergenic, natural, clinically proven or dermatologically tested must be backed by evidence under the common criteria for cosmetic claims.
Because Omnibus updates apply without a grace period, repeat the screen at the production date and again before the booking is confirmed. Add a nanomaterial check at the same time, so that any Article 16 notification is dealt with before it can delay the launch.
Stage two: appoint the Responsible Person and file
Appoint the Responsible Person in writing, commission the safety report from a qualified assessor and assemble the Product Information File. Filing itself runs through the Commission’s tools: the Responsible Person’s designated user needs a personal EU Login account and then requests access to the CPNP for the organization through the Commission’s authorization system. Access is personal, so a departing employee can leave a gap that nobody notices until a product needs updating.
Timing is the part most often misunderstood. The Regulation requires notification before a product is placed on the market, and for imports that moment arrives when the goods are released for free circulation. The notification therefore has to exist before the cargo clears, and ideally before it sails. A practical rule for forwarders is to hold booking confirmation until the reference number has been shared.
Stage three: check the finished goods against the file
A compliant file means little if the goods do not match it. Once production is complete, compare the finished products with the artwork submitted to the portal, and confirm that batch numbers, periods after opening and Responsible Person addresses are correct on every unit and on the outer cartons. Check the language requirements of the destination country. Ask the packaging supplier for the PPWR declaration of conformity for each packaging type, especially where the brand’s own name appears on the pack.
Finally, confirm that the product names on the invoice and packing list are the same names that appear on the label and in the CPNP record. Customs lines and, from November, product identifiers will be built from that description, and any mismatch invites a query.
Stage four: build the document pack
The last stage is assembling one consistent set of documents that travels with the shipment and is shared with the customs broker and the consignee. Table 3 shows what a cosmetics pack should contain and why each item matters.
Table 3. Recommended document pack for a cosmetics shipment to the EU
| Document | Prepared by | Why it matters at the border or the warehouse |
| Commercial invoice with product names matching the label | Exporter | Customs lines and product identifiers are built from the description and value |
| Packing list with SKUs, batch numbers and carton counts | Exporter or factory | Lets inspectors and receiving teams match cargo to the notification |
| CPNP reference per product and Responsible Person details | Responsible Person | Shows the product was notified; requested by importers and marketplaces |
| Written confirmation that the safety report and information file exist | Responsible Person | A legal precondition for import, even though customs rarely open the file |
| Label and packaging artwork | Brand or factory | Compared against portal images and language requirements |
| Safety Data Sheets and flash-point data | Manufacturer | Determines whether the cargo is dangerous goods and how it must be packed |
| PPWR packaging declarations of conformity | Packaging supplier or brand | Needed for each packaging type placed on the market since 12 August 2026 |
| Origin declaration | Exporter | Origin must be consistent across the label, the notification and the customs declaration |
Shipping Realities for Cosmetics
Flammables, aerosols and other dangerous goods
Many cosmetics are dangerous goods in transport even though they sit harmlessly on a bathroom shelf. Aerosol hair sprays, dry shampoos and deodorant sprays, alcohol-based perfumes and colognes, nail polish and removers, some hair colorants and beauty devices with lithium batteries can all fall under the IMDG Code at sea, IATA rules by air and ADR on European roads. Carriers expect accurate declarations, approved packaging and correct marking, and a misdeclared shipment can be refused, delayed or removed from a vessel at the shipper’s expense.
The Safety Data Sheet and the flash point are the starting data, and they should be collected before a quote is issued, not after the booking is made. Limited-quantity rules can simplify the handling of small inner packs, but only when the packaging and marking are exactly right.
Heat, cold and shelf life
Sea transit through warm latitudes exposes cargo to conditions well above what most product stability tests assume. Emulsions can separate, closures can leak and alcohol-based products can build pressure. In winter the opposite risk appears on inland legs to northern and eastern Europe, where water-based formulas can freeze. Palletize cartons properly, ask for below-deck or shaded stowage where the carrier can accommodate it, and make sure the stability data in the Product Information File covers realistic transport conditions.
FCL, LCL or parcel: choosing the right model
Full container load suits a brand with enough volume to fill a box and a single consignee. One Responsible Person, one document pack and one clearance keep the process simple, although the flip side is that a hold on any part of the cargo can affect the whole container.
Less-than-container-load works well for smaller replenishment orders and for testing a new market, but cargo is consolidated with other shippers’ goods and handled at both ends. Every consignment needs its own complete file, and it pays to be careful with scent and leakage. Strongly fragranced goods can taint neighboring cartons, and a leaking bottle can spoil a pallet that has nothing to do with it.
Express and postal parcels serve direct-to-consumer orders, samples and urgent restocks. They are fast and flexible, but they also sit squarely inside the new item-level duty and identifier regime, and air carriers apply the strictest dangerous-goods limits. Table 4 compares the three models.
Table 4. Comparing shipping models for cosmetics into the EU
| Mode | Best suited to | Compliance considerations | Main watch-outs |
| FCL ocean freight | Regular replenishment to an EU warehouse or prep center | One consignee and Responsible Person; document pack reviewed once | Whole container exposed to a single hold; heat during transit |
| LCL ocean freight | Smaller B2B orders and market testing | Each consignment needs its own complete file | Extra handling at both ends; scent and leakage contamination |
| Express or air parcel | Direct-to-consumer orders, samples, urgent restocks | Item-level lines, product identifiers, €3 duty and the expected handling fee | Strictest dangerous-goods rules; per-line costs hit low-value items hardest |
Getting the Landed Cost Right in the New Era
Cosmetics fall under HS chapter 33. Heading 3303 covers perfumes and toilet waters, 3304 covers beauty, make-up and skin-care preparations, 3305 covers hair preparations, 3306 covers oral and dental hygiene products and 3307 covers shaving products, deodorants and bath preparations. Soap belongs elsewhere, under 3401. Ordinary duty rates on many chapter 33 lines are low or zero, so for a pallet moving business to business the duty is rarely the largest cost. Freight, VAT and the cost of the Responsible Person and safety documentation usually weigh more, but always verify current rates in the EU’s TARIC database before quoting.
The new flat duty turns that logic upside down for direct-to-consumer parcels. A fixed €3 per item line can easily exceed the ordinary tariff on an inexpensive cosmetic. Consider a €40 order with a serum, a lip balm and a shampoo, each falling under a different six-digit subheading. That is three declaration lines and €9 of duty. If the handling fee arrives at €2 per line, another €6 follows, so the order carries €15 of border charges before VAT, roughly 37 percent of its value.
Lines can be consolidated only when the goods share the same six-digit classification, country of origin and description, and no one should ever bend a declaration to save a few euros. The commercial lesson is to model cost per declaration line, not per parcel. Larger bundles, business-to-business replenishment of EU warehouse stock and carefully planned assortments may beat single-item parcels, and all of these figures remain subject to the final implementing legislation.
How Topway Shipping Supports Cosmetics Exporters
Since 2010, Topway Shipping has provided cross-border e-commerce logistics solutions from its headquarters in Shenzhen, China. Our founding team brings more than 15 years of experience in international logistics and customs clearance, with a strong focus on China–U.S. transportation. That background is relevant to cosmetics, because a heavily regulated consumer market teaches a logistics provider early what it takes to move sensitive goods: accurate documents, disciplined classification and no surprises at the border.
Our services span the entire logistics chain, including first-leg transportation, overseas warehousing, customs clearance and last-mile delivery. For sea freight we offer flexible full-container-load and less-than-container-load services from China to major ports worldwide. That flexibility lets a cosmetics brand choose the container strategy that fits its volume and its compliance file, instead of forcing every product into the same mold.
What we do not do is replace the Responsible Person. The CPNP notification, the safety report and the information file belong to the Responsible Person and qualified assessors, and any provider that promises to handle them invisibly inside a freight quote deserves a second look. What a logistics partner can do is make sure the shipping process respects the compliance file. That means asking for CPNP references and Responsible Person details before quoting, checking that invoice and packing-list descriptions match the labels, requesting Safety Data Sheets for dangerous-goods screening, and keeping cartons and batches organized for inspection. When a shipment is questioned, having one partner across the origin, the sea leg, customs clearance and delivery shortens the loop for getting answers.
If you are planning a first cosmetics shipment to Europe, send us your product list, HS classifications, Safety Data Sheets and your Responsible Person’s details before you book. It is far cheaper to hear what is missing while the cargo is still at the factory than after it reaches the terminal.
Mistakes That Keep Costing Cosmetics Shippers Money
The most expensive mistake is assumption. Factories assume brands file, brands assume importers file, and importers assume the supplier’s email signature is proof. The fix is to name one Responsible Person in writing before production and to see the notification record with your own eyes before booking freight.
The second mistake is treating the reference number as a lifetime pass. A notification does not protect a product from Omnibus bans, new allergen labeling or packaging rules, and an outdated record can be as damaging as a missing one. Diarize the regulatory dates in Table 2 and ask the Responsible Person to confirm the status of each product before every new production run.
The third is operational: ignoring transport reality. Cosmetics that are undeclared dangerous goods, cartons that overheat in a container stack, and labels that were changed at the last minute without updating the portal all create problems that no amount of customs expertise can repair after the cargo has sailed. Compliance and logistics have to be planned together, on the same calendar.
Conclusion
The CPNP notification is not complicated, but it is unforgiving of assumptions. It is a legal precondition for putting a cosmetic product on the EU market, it can only be made by an EU-based Responsible Person, and it is checked by customs, marketplaces and retailers who now have better data and stronger incentives than ever. A reference number issued in seconds is only the visible tip of a safety report, an information file, a compliant label and a packaging declaration.
The 2026 changes make the stakes higher. Omnibus VIII bans took effect without a grace period, new allergen labeling and packaging rules are arriving, and the €3 duty, product identifiers and expected handling fee put every declaration line under a microscope. Brands and forwarders that build compliance into the shipping timeline will spend less on storage, re-labeling and returns than those who discover the requirement at the port.
If you want a logistics partner that respects your compliance file and can carry it through first-leg transportation, ocean freight, customs clearance, overseas warehousing and last-mile delivery, Topway Shipping is ready to help you plan the route before the cargo moves.
FAQs
Q: Who is allowed to file a CPNP notification?
A: Only the Responsible Person established in the EU can submit it. A factory, a forwarder or a marketplace seller cannot file unless it is also the designated Responsible Person for that product.
Q: Does it cost anything to use the CPNP?
A: The portal itself is free. The real costs come from the Responsible Person service, the safety assessment, testing and label work that must be completed before you can notify.
Q: Is there a minimum shipment or company size below which notification is not needed?
A: No. Commercial guidance is consistent that there is no exemption based on company size or sales volume, so even a small first shipment needs a Responsible Person and a notification.
Q: If my product was notified before Omnibus VIII, is it still legal?
A: Only if the formula complies with the new rules. Products containing newly banned or restricted substances had to leave the market from 1 May 2026, so ask your Responsible Person to confirm and update the record if needed.
Q: Does the €3 duty apply to pallets sent to an EU warehouse?
A: The flat duty targets low-value consignments of €150 or less sold by non-EU sellers registered for IOSS. Bulk business-to-business freight follows the ordinary rules, but you should confirm your case with a customs broker.
Q: Can Topway Shipping file our CPNP notification?
A: No, that task belongs to your Responsible Person. Topway Shipping handles the logistics chain, including first-leg transportation, FCL and LCL ocean freight, overseas warehousing, customs clearance and last-mile delivery, and works from the compliance documents your Responsible Person provides.