CPNP and EU Rules for Selling Korean Cosmetics

What CPNP means

CPNP is the Cosmetic Products Notification Portal, a free online system created for the implementation of Regulation (EC) No 1223/2009 on cosmetic products. The European Commission states that once a product has been notified there, no further notification is needed at national level within the EU. Competent authorities and poison centres can see the data for market surveillance and medical treatment.

Article 13 of the Regulation sets out what the Responsible Person submits before placing a product on the market:

• the product category and name
• the name and address of the Responsible Person
• the country of origin, for imported products
• the Member State where the product will be placed on the market
• a contact person for emergencies
• nanomaterials and certain CMR substances, where present
• the frame formulation

When the product reaches the market, the Responsible Person also notifies the original label and, where legible, a photo of the packaging. The portal is available on the European Commission’s CPNP page, and the notification itself is made in the CPNP portal.

Who must notify: the Responsible Person

The Responsible Person is the legal or natural person designated within the EU for each cosmetic product. Article 4(1) says only products with such a designated person may be placed on the market. The person ensures compliance with the Regulation (Article 4(2)) and carries the duties listed in Article 5, including the safety assessment, the product file, notification, labelling and claims.

Who that person is depends on how the product reaches the EU:

A Korean brand cannot act as Responsible Person from Korea, because the person must be established in the EU.

What a retailer of Korean cosmetics should check before selling

A reseller is a distributor under Article 2(1)(e): a person in the supply chain, other than the manufacturer or importer, who makes a product available on the market. Article 6 requires distributors to act with due care and, before making a product available, to verify three things:

• the labelling information in Article 19(1)(a), (e) and (g) and Article 19(3) and (4) is present
• the language requirements of Article 19(5) are met
• the date of minimum durability, where applicable, has not passed

Article 6 also says a distributor must not make a non-conforming product available until it is brought into conformity, and must keep storage and transport conditions that do not jeopardise compliance. The obligations behind the label sit with the Responsible Person, so the practical checklist for a shop starts with the label and the supplier.

Labelling and language

Article 19(1) lists what must appear on the container and packaging:

• Name and address of the Responsible Person, plus the country of origin for imported products
• Nominal content (weight or volume)
• Date of minimum durability, or for products with a durability over 30 months, the period after opening (PAO) shown with the open-jar symbol
• Precautions for use
• Batch number
• Function of the product, unless clear from its presentation
• List of ingredients, preceded by the word “Ingredients”

Article 19(5) says the language of the nominal content, durability, precautions and function is decided by the law of the Member State where the product is made available to the end user. Member States set their own rules, so check the national requirement for each country you sell in. Ingredient names follow the common ingredient name from the glossary under Article 19(6), which is the INCI naming system most cosmetic labels use.

Safety file and ingredient rules

Before placing a product on the market, the Responsible Person must ensure a safety assessment and a Cosmetic Product Safety Report (Article 10). A Product Information File (PIF) is kept for ten years after the last batch is placed on the market (Article 11), and must be accessible at the address on the label. It includes the safety report, the manufacturing method with a good-manufacturing-practice statement, proof of claimed effects where justified, and animal-testing data.

Article 14 restricts ingredients: products must not contain substances listed in Annex II, restricted substances in Annex III must stay within their limits, and colorants, preservatives and UV filters must follow Annexes IV, V and VI. Claims must not imply characteristics the product lacks (Article 20). Sun care and active-heavy products deserve particular attention, since UV filters have their own annex.

Buying from an EU wholesaler versus importing from Korea

When you buy from a wholesaler established in the EU, the products are normally already on the EU market and a Responsible Person already exists. Your role is that of a distributor, and the checks above apply. You still need to read the label on delivered stock and confirm that the Responsible Person’s name and address are there.

When you import from Korea yourself, you place the product on the EU market, so you are the importer. Article 4(5) makes each importer the Responsible Person for the specific product it imports, unless it appoints an EU-established person by written mandate. That means the notification, the safety report and the product file become your responsibility, or that of the person you appoint.

If you change the product or sell it under your own brand, Article 4(6) makes you the Responsible Person. Translating information about a product already on the market does not count as such a modification, although in certain cases it triggers a distributor notification under Article 13(3).

CPNP access and registration basics

Responsible persons and distributors both have access to the CPNP. According to the portal’s help pages, users select a user profile, an organisation administrator validates access requests, and the Commission provides user guides for responsible persons and distributors. There is a separate module under Article 16 for products containing nanomaterials, in addition to the Article 13 notification.

Retail shops that only resell products on the EU market usually do not need to create notifications. If you plan to import, appoint a Responsible Person first, because they hold the product file and submit the notification.

UK note

Great Britain operates its own system. GOV.UK states that products made available to consumers in Great Britain must be notified through the Submit cosmetic product notifications (SCPN) service, and that the Responsible Person must be established in the UK, without using a mail-forwarding or PO box address. Northern Ireland has a separate process. Read the GOV.UK guidance on submitting a cosmetic product notification before selling in the UK, and note that an EU CPNP notification is not a UK one.

Practical checklist

The full legal text is in Regulation (EC) No 1223/2009 on EUR-Lex. This page summarises what the Regulation requires and is not legal advice; confirm your obligations with your supplier and the Responsible Person.

Where to source from within the EU

Sourcing from an EU-based supplier keeps you in the distributor role. Gemer Wholesale is a B2B supplier operated by Gemer Grupp OÜ in Tallinn, Estonia. Ask the supplier for the Responsible Person details of each brand you plan to stock. You can compare Korean cosmetics wholesalers in Europe on the homepage, or go to Gemer Wholesale directly. Our guide to Korean skincare wholesale in Europe covers ordering terms and product types.