Brands preparing to sell in the EU often use "CPNP," "PIF," and "CPSR" as if they mean the same thing. They don't. They are three layers of one system, one inside the other. Not knowing this causes a common problem: a brand finds out mid-project that a document is their job, not their manufacturer's job.
This article breaks down the three layers. It also shows who provides each document.
1. The Three Layers
- CPNP (Cosmetic Products Notification Portal). This is the EU registration platform. Every cosmetic product sold in the EU must be notified here before it goes to market.
- PIF (Product Information File). This is the full document package that CPNP registration requires. It must be kept on file. Authorities can request it at any time.
- CPSR (Cosmetic Product Safety Report). This is one part of the PIF. It has two sections: Part A (safety data) and Part B (the safety assessor's conclusion).
In short: CPNP is the registration. PIF is the full file behind it. CPSR is the safety section of that file.
2. CPSR Part A — Data Requirements
Part A collects the raw safety data. A safety assessor will review this data later. The requirements fall into three groups.
Mandatory:
| Item | Provided by |
|---|---|
| Finished product INCI | Manufacturer |
| Raw material SDS | Raw material supplier |
| Raw material CoA | Raw material supplier |
| Fragrance IFRA certificate | Fragrance supplier |
| Fragrance SDS | Fragrance supplier |
| Fragrance allergen declaration | Fragrance supplier |
| Microbial testing | Manufacturer / testing lab |
Recommended:
| Item | Provided by |
|---|---|
| Finished product SDS | Manufacturer |
| Finished product CoA | Manufacturer |
Conditional or optional:
| Item | Condition | Provided by |
|---|---|---|
| Preservative challenge test | Required if the formula is preserved | Manufacturer / testing lab |
| Heavy metals testing | Optional | Manufacturer / testing lab |
| Fragrance INCI | Only if the client asks for full disclosure | Fragrance supplier |
Most of Part A comes from suppliers and manufacturers. A brand's own job here is small. In most cases, it is just deciding whether to request full fragrance INCI disclosure.
3. CPSR Part B — Who Writes the Conclusion
Part B is where a qualified safety assessor reviews the Part A data and gives a conclusion:
- Toxicological conclusion
- Labeling recommendations
- Justification
- Assessor's credentials
All four items come from the safety assessor. Not from the brand. This is normally arranged through the manufacturer or CDMO. A brand does not need to find its own safety assessor, unless it wants an independent one.
4. What Else the PIF Requires
The PIF has more documents outside the CPSR. Here they are, grouped by who provides them.
Manufacturer provides:
- GMP compliance certificate (GMPC)
- Manufacturing process description
- Animal testing statement
- Stability testing report, including packaging compatibility
Brand provides:
- Efficacy claim substantiation, if the product makes a functional claim
- Product name and category
- Nanomaterial declaration
- Children's use declaration
- Label and packaging artwork
- Responsible person information
Material supplier provides:
- Packaging material technical data sheet (TDS). Required only if a food-contact claim applies.
5. The Logic Behind It
The rule is simple: whoever creates the data must provide it. Manufacturers own the process and stability data. Suppliers own the raw material and fragrance data. Safety assessors own the conclusion. What the brand owns directly is smaller than most people expect. Mainly: labeling, responsible person designation, and any efficacy claims the brand itself makes.
Disclaimer: Regulatory requirements vary by product type, market, and formulation. This overview is for general reference only. It does not replace guidance from a qualified regulatory or safety assessment professional.
