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If I notify in CPNP, do I still need to notify each EU country separately?
I understand CPNP is a centralized system, but I'm unclear if I still need to submit separate notifications to individual EU member states. Does CPNP cover all EU countries, or are there additional national requirements?
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Asked by Lo H. Khamis
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Lo H. Khamis, Regulatory Experts
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## If I Notify in CPNP, Do I Still Need to Notify Each EU Country Separately?
**Generally, no—CPNP is designed so that once a product is notified in CPNP, no additional national notification is needed within the EU.** However, understanding the exceptions and nuances is important.
### The General Rule
According to Article 13 of Regulation (EC) No 1223/2009, CPNP is a **centralized notification system**<sup><a href="#cite-9">[1]</a></sup>. Once you notify a product in CPNP:
- ✅ The notification is automatically shared with all EU member state competent authorities
- ✅ No additional national notifications are typically required
- ✅ One notification covers all EU countries
### How CPNP Works
CPNP is designed to:
1. **Centralize notifications** - One system for all EU member states
2. **Share automatically** - Notifications are automatically shared with competent authorities
3. **Eliminate duplication** - No need to notify each country separately
4. **Streamline compliance** - Simplifies the notification process
### Exceptions and Additional Requirements
While CPNP covers the EU-wide notification requirement, some considerations:
**Language Requirements:**
- Some countries may require product information in local languages
- Check specific country requirements for labeling and documentation
**Additional Documentation:**
- Some countries may request additional documentation beyond CPNP
- Be prepared to provide supplementary information if requested
**National Market Surveillance:**
- Individual countries may conduct their own market surveillance
- Authorities may request additional information specific to their market
### CPNP Coverage Checklist
Verify CPNP covers your needs:
- [ ] CPNP notification is submitted before market placement
- [ ] Notification includes all required information
- [ ] Notification is shared with all EU member state authorities
- [ ] No additional national notifications are required (verify for your target markets)
- [ ] Language requirements are met for target countries
- [ ] Additional documentation is available if requested
### Practical Considerations
**For Multi-Country Sales:**
- CPNP notification covers all EU countries
- No need to submit separate notifications per country
- Verify language and labeling requirements per country
**For Single-Country Sales:**
- CPNP notification still required
- Covers EU-wide requirement
- May need to meet country-specific language requirements
### Common Misconceptions
**❌ "I only sell in one EU country, so I don't need CPNP"**
- **Reality:** CPNP is required regardless of how many countries you sell in
**❌ "I need to notify each country separately"**
- **Reality:** CPNP covers all EU countries with one notification
**❌ "CPNP is optional"**
- **Reality:** CPNP notification is mandatory before market placement
### Best Practices
1. **Submit CPNP notification** before placing products on any EU market
2. **Verify coverage** - Confirm CPNP covers your target markets
3. **Check language requirements** - Ensure compliance with country-specific language needs
4. **Maintain CPNP access** - Keep RP's CPNP access active
5. **Update promptly** - Update CPNP when products or information changes
### Next Steps
1. Understand CPNP covers EU-wide notification
2. Verify any country-specific requirements for your target markets
3. **[Compare EU Cosmetics Responsible Person providers & request quotes](https://cruxi.ai/regulatory-directories/cosmetics_rp)** - Find providers experienced with multi-country CPNP notifications
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*Written by **Lo H. Khamis**, Regulatory Experts. [Connect on LinkedIn](https://www.linkedin.com/in/lo-h-khamis) for regulatory guidance.*
### Official Sources:
<a id="cite-9"></a>[1] [Regulation (EC) No 1223/2009 - Article 13](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)
- [European Commission - CPNP portal](https://single-market-economy.ec.europa.eu/sectors/cosmetics/cosmetic-products-notification-portal_en)