Prior to placing a cosmetic product on the market the responsible person must submit, by electronic means via the Cosmetic Products Notification Portal (CPNP), the following information to the Commission:
- the category of cosmetic product and its name or names, enabling its specific identification;
- the name and address of the responsible person where the Product Information File (PIF) is made readily accessible;
- the country of origin in the case of import;
- the Member State in which the cosmetic product is to be placed on the market;
- the contact details of a physical person to be contacted in case of necessity;
- any nanomaterials which are present in the product;
- the formulation, which can be framed with ranges or exact concentrations, to allow for prompt and appropriate medical treatment in the event of difficulties;
- original labelling and a photograph of the packaging;
A useful tutorial can be found here: CPNP Tutorial
The CPNP user manual can be found here: CPNP User Manual
To begin, Product Notification consists of a few steps:
- ECAS website – to register individual users: Self Reg
- SAAS website – to set up organisation profiles. To link individual users to organisations: SAAS
- CPNP website – to submit your product details: CPNP
As a complimentary service our CPSRs also list the CPNP designated Frame Formulation number for you which saves you having to enter each formulation into the CPNP. There are 140 different Frame Formulations.
If the responsible person selects ‘predefined frame formulation’, the CPNP will automatically propose the corresponding predefined frame formulation on the basis of the category and formulation name selected by the responsible person. This predefined frame formulation will be linked to the notification as a PDF document. This PDF document can be opened by the responsible person in order to check its relevance for the product being notified by clicking on Adobe Acrobat image.
Rules of particular note
Rule 5: Chemical exfoliation products containing chemical exfoliating agent(s) (e.g. lactic acid, glycolic acid, salicylic acid)
The INCI name and the concentration of chemical exfoliating agent(s) must be specified. An updated notification is required when the concentration changes by more than 20% of the value declared previously.
Rule 6: Products containing vitamin A and derivatives (e.g. retinol, retinyl esters)
The exact content of vitamin A or any of its derivatives must be specified if the level exceeds 0.20 % (calculated as retinol) or if the amount exceeds 0.09 grams (calculated as retinol) for the whole product. An updated notification is required when the concentration of vitamin A or derivatives changes by more than 20% of the value declared previously. If the level of vitamin A or any of its derivatives does not exceed 0.20% (calculated as retinol) or if the amount does not exceed 0.09 grams (calculated as retinol) or if vitamin A or any of its derivatives are not present in the product, then ‘not applicable’ must be checked.
Oxford Biosciences note: Although retinyl esters (e.g. retinyl palmitate) are limited in Norway, the SCCS currently does not restrict their amount in cosmetic products. This handy guide can be used to determine the level of retinol in order to enter an accurate percentage amount into the CPNP:
Retinol Equivalent (RE) where:
1 µg RE = 1 µg retinol = 1.78 µg retinyl palmitate = 6 µg ß-carotene = 12 µg other carotenoids with provitamin A activity = 3.33 IU vitamin A activity from retinol
To calculate your RE, multiply your w/w% of retinyl palmitate by 0.562. Therefore if your formulation has 2g of retinyl palmitate (2% w/w) then that is an RE of 1.12%.
The Retinol Consortium has made some excellent and positive points on the use of RE in cosmetics. You may be interested in reading “Answer to the objections from The Retinol Consortium to VKM’s document Risk assessment of vitamin A (retinol and retinyl esters) in cosmetics” published by Vitenskapskomiteen for mattrygghet (VKM), The Norwegian Scientific Committee for Food Safety, in English here: Retinol VKM
As a complimentary service our CPSRs also calculate the RE for you.
Rule 8: Products containing cationic surfactants with two or more chain lengths below C12
The INCI name and the concentration of cationic surfactants with two or more chain lengths below C12 must be specified if the surfactant is used for non preservative purpose. An updated notification is required when the concentration changes by more than 20% of the value declared previously.
Typical examples of cationic surfactants covered by this rule:
• behentrimonium chloride
• distearyldimonium chloride
• cetrimonium chloride
• dicetyldimonium chloride
If cationic surfactants with two or more chain lengths below C12 are not present in the product, then ‘not applicable’ must be checked.
Rule 17: Products containing essential oils, camphor, menthol or eucalyptol*
Except for perfume and some limited other product categories, when a manufacturer introduces in a formula essential oils, camphor, menthol or eucalyptol with a total level higher than 0.5%, the total level concentration must be indicated. If essential oils, camphor, menthol or eucalyptol are not present in the product or if the total level of essential oils, camphor, menthol and eucalyptol does not exceed 0.5%, then ‘not applicable’ must be checked. For each individual essential oil and camphor, menthol or eucalyptol with a level higher than 0.5% (0.15 % in case of camphor), the manufacturer must state the name and quantity of this essential oil/essential oil derivative. If no individual essential oil, camphor, menthol or eucalyptol are present with a level higher than 0.5% (0.15 % in case of camphor), then ‘not applicable’ must be checked. An updated notification is required when the concentration changes by more than 20% of the value declared previously.
* Eucalyptol is more commonly known as 1,8-cineol