## Background EU Cosmetics Regulation (EC) No 1223/2009 requires that cosmetics complete notification through CPNP (Cosmetic Products Notification Portal) before being placed on the EU market. The notification itself does not produce a certificate, but it is a prerequisite for legal product launch. Since 2026, competent authorities in several EU member states have strengthened verification of consistency between notified information and actual products during market spot checks, resulting in some notified products being required to supplement materials or even being removed from shelves. In the CPNP filing follow-up over the past six months, the Shuwang Testing and Certification Platform has observed a rise in the return rate compared with before, with problems concentrated in the correspondence between ingredients and labels.
## Frontline Observations From the cases we have handled, the reasons for return can be roughly divided into four categories:
| Problem Type | Typical Manifestation | Common Consequence | | --- | --- | --- | | Ingredient list inconsistent with label | Label INCI names do not match the notification entries, or fragrance allergens are not labeled | Correction of notification required, product launch suspended | | Nanomaterials not declared | Formula contains nano-scale raw materials but the corresponding item is not checked in the notification | Supplementary safety assessment required, timeline extended | | Responsible person information missing | Changes to the EU Responsible Person (RP) address or contact details not updated | Notification status abnormal, customs clearance blocked | | CPSR disconnected from notification | Safety assessment report version predates formula adjustment | CPSR needs to be reissued |
Among these, inconsistency between the ingredient list and label is the most common reason for return. When some companies switch to new formulas, they only update the internal BOM without synchronously modifying the label and notification, causing deviations among the three. Another high-frequency issue is fragrance allergens: the EU requires labeling when allergen concentration exceeds 0.001% in leave-on products and 0.01% in rinse-off products, but many companies still operate according to old label templates.
## What Companies Should Do First, establish a version cross-reference table for formula, label, and notification, so that any formula adjustment triggers a review of the label and notification. Second, complete the final version of the CPSR before notification to ensure that the safety assessment conclusions are consistent with the notified ingredients. Third, for products containing fragrance, check the concentration and labeling obligations of the 26 allergens item by item. Fourth, when the EU Responsible Person information changes, update it in CPNP in a timely manner to avoid questions during customs clearance.
The Shuwang Testing and Certification Platform provides document pre-review and RP liaison services in the CPNP filing process, assisting companies in identifying deviations between ingredients and labels before submission. The industry reference period for CPNP notification is 5–10 working days, and the reference fee range is RMB 3,000–8,000, subject to the complexity of the product formula and RP scheduling. For more information, visit https://www.shuwang-cert.com.
## Notes The changes in review standards described in this article are based on frontline filing experience; specific technical requirements are subject to the original text of EU regulations and the interpretations of competent authorities in each country. CPNP notification is submitted by the EU Responsible Person. The Shuwang Testing and Certification Platform does not engage in testing activities and is not a certification body; it only provides document preparation, RP liaison, and submission follow-up services.