Selling Cosmetics in the EU and UK: Responsible Person, CPNP, SCPN and the Product Information File

Europe has become one of the fastest-growing destinations for Korean cosmetics. According to Korean trade ministry data reported in July 2026, exports to the EU rose 76.3% in the first half of 2026, to about US$0.90 billion, against about 27% growth across all markets. For brands following that demand, CPNP notification is the best-known requirement, but it is the fourth of five steps.

Since Brexit, the EU and Great Britain have been separate regimes. The EU applies the EU Cosmetic Products Regulation, Regulation (EC) No 1223/2009, while Great Britain runs its own notification service and requires its own Responsible Person.

Step 1: Appoint a Responsible Person

Under Article 4 of the regulation, a cosmetic product may only be placed on the EU market if a legal or natural person established in the EU is designated as its Responsible Person (RP). For an imported product, the importer is the RP by default. The importer may instead designate another EU-established person by written mandate, which that person accepts in writing.

The RP’s name and address appear on the label, and the RP keeps the product file available at that address. That is why this decision comes first: it shapes the label artwork, the paperwork and who answers to the authorities.

Step 2: Safety Assessment and the CPSR

Before launch, the RP must ensure a safety assessment has been carried out and a cosmetic product safety report (CPSR) prepared in line with Annex I of the regulation (Article 10). The assessor must hold a qualification in pharmacy, toxicology, medicine or a similar discipline.

Much of the input comes from the manufacturer. Annex I covers, among other points:

• Qualitative and quantitative composition
• Physical and chemical characteristics and stability
• Microbiological quality
• Impurities, traces and packaging material information
• Foreseeable use, exposure and the toxicological profile of the ingredients

For example, a brand launching a Korean-made serum would typically obtain the formula, raw-material specifications, stability and microbiological data from its manufacturer for the assessor.

Step 3: Build the Product Information File

The RP keeps a Product Information File (PIF) for each product for 10 years after the last batch is placed on the market (Article 11), at the address on the label. It contains:

• A description of the product
• The CPSR
• A description of the manufacturing method and a statement on compliance with good manufacturing practice (GMP)
• Proof of the claimed effect, where justified
• Data on any animal testing

The GMP statement usually comes from the manufacturer. Article 8 presumes GMP compliance where manufacture follows the relevant harmonized standards, so ask your partner which GMP certification it holds.

Step 4: CPNP Notification (EU) and SCPN (Great Britain)

Before the product goes on sale, the RP notifies it through the European Commission’s Cosmetic Products Notification Portal (CPNP). The CPNP is free, and once a product is notified there is no need for further national notification within the EU. The notification covers details such as the product category and name, the RP, the country of origin for imports, any nanomaterials and the frame formulation.

What buyers often call cosmetic product registration in the UK is an SCPN notification. Before products reach consumers in Great Britain, a UK-established RP must notify them through the Submit Cosmetic Product Notifications (SCPN) service. UK guidance also requires an English-language PIF and the RP’s UK address on the label. Northern Ireland follows separate rules, with a Responsible Person established in Northern Ireland or the EU.

Step 5: Labels and Claims

Article 19 sets the EU label elements, including:

• The RP’s name and address
• Country of origin for imported products
• Nominal content
• Date of minimum durability or, for products lasting over 30 months, the period after opening
• Precautions, batch number and function
• The ingredient list, with fragrance shown as “parfum” or “aroma” and listed allergens named

The label language is set by each Member State where the product is sold, so a multi-country launch may need several language versions.

Claims must meet the common criteria in Regulation (EU) No 655/2013, including truthfulness, evidential support and fairness. An ingredient claim must not imply the finished product has that ingredient’s properties when it does not, and claims must not denigrate legally used ingredients. The EU technical document on cosmetic claims, non-binding guidance for authorities, says “free from parabens” should not be accepted.

What Is Changing

As of October 2026, four developments stand out for EU launches:

• Fragrance allergens. Regulation (EU) 2023/1545 extends individual allergen labeling. Non-compliant products could be placed on the market until 31 July 2026 and made available until 31 July 2028, so products placed on the market after that date need the expanded labeling.
• Packaging. The Packaging and Packaging Waste Regulation (EU) 2025/40 applies from 12 August 2026 to all packaging placed on the EU market, regardless of origin. Factor it into your packaging choices.
• Simplification. In June 2026 the Council and the European Parliament reached a provisional political agreement on Omnibus VI, an EU simplification package that includes cosmetics. It still needs formal adoption, so check its status before planning labels around it.
• Ingredient restrictions. Banned and restricted ingredient lists change over time. In the Commission’s Safety Gate report for 2025, cosmetics were the most-notified category, at 36% of a record 4,671 alerts, and nearly 8 in 10 cosmetics alerts involved BMCHA, a synthetic fragrance ingredient banned in the EU.

Do not assume an EU change applies in Great Britain, or the reverse. Check each regime separately.

What Your Manufacturer Provides vs. What Your RP Does

Your OEM/ODM partner holds the technical data; your RP holds the legal responsibility.

Your manufacturer typically provides:

• Formula data and the full ingredient list
• Stability, compatibility and microbiological data
• Raw-material specifications and safety data sheets
• The manufacturing method and a GMP statement
• Batch documents such as a Certificate of Analysis (COA)

Your Responsible Person:

• Holds the role as importer or by written mandate
• Has a qualified assessor complete the CPSR
• Keeps the PIF for 10 years after the last batch
• Submits the CPNP or SCPN notification before sale
• Checks labels, languages and claims, and updates the file when the formula or label changes

Frequently Asked Questions

Can my Korean manufacturer be my EU Responsible Person?

Not from Korea. The RP must be established in the EU. For imported products, the importer is the RP by default or designates another EU-established person in writing. Your manufacturer supplies the data the RP needs.

Does one CPNP notification cover the UK?

No. The CPNP covers the EU. Great Britain requires a separate SCPN notification by a UK-established RP.

How long must I keep the PIF?

In the EU, 10 years after the last batch is placed on the market. UK guidance also sets 10 years.

Final Thoughts

Selling cosmetics in Europe is manageable once you follow the sequence: Responsible Person, safety assessment, PIF, CPNP notification or SCPN, then labels. Appoint your RP before you lock the label, because the RP’s address and the language versions depend on that decision.

This is an overview as of its sources’ dates, not legal advice. Confirm current rules with the authorities or a regulatory consultant before you launch.