If you distribute professional cosmetics made in Spain in another European Union country, you do not have to register them again: the notification the manufacturer files on the EU's CPNP portal covers the whole single market. The only notification duty that can fall on you arises if you translate the labelling on your own initiative.
What Does the Manufacturer's CPNP Notification Cover?
Before a cosmetic is sold in the EU, the product's responsible person notifies it on the CPNP, the European Commission's notification portal. That notification is a one-off: as the Commission explains on its CPNP page, once a product has been notified there is no need for any further notification at national level within the EU.
For a distributor in another Member State, that makes the start much simpler. There is no country-by-country health registration and no customs between Member States: the product that leaves Tudela reaches your warehouse with the same legal status it had in Spain.
Who Answers for the Product, and What the Distributor Does
The key figure in Regulation (EC) No 1223/2009 on cosmetic products is the responsible person. For a product manufactured in the EU, that is the manufacturer established in the EU, which ensures safety, the product information file and the notification.
The distributor has a different role, which the regulation sums up as acting with due care:
| Who | What falls to them |
|---|---|
| Manufacturer (responsible person) | Safety, product file and CPNP notification |
| Distributor | Checking labelling, language and durability date |
| Distributor | Storing and shipping without affecting compliance |
| Distributor translating on its own | Submitting its own notification |
A distributor only becomes the responsible person if it places the product on the market under its own name or trademark, or modifies it in a way that could affect compliance. The regulation makes clear that translating the product information is not considered such a modification.
When Does the Distributor Have to Notify?
The language of the labelling is set by the law of each Member State where the product is sold, so distributing in another country usually means labels in its language. That is where the distributor's only CPNP obligation of its own comes in, in Article 13 of the regulation:
As from 11 July 2013, a distributor who makes available in a Member State a cosmetic product already placed on the market in another Member State and translates, on his own initiative, any element of the labelling of that product in order to comply with national law, shall submit, by electronic means, the following information to the Commission.
The information is brief:
- Product
- category and name in each country
- Country
- the Member State where it is sold
- Distributor
- your name and address
- Responsible person
- name and address of the file
The key lies in the phrase on his own initiative. Before signing, clarify with the manufacturer who prepares the labelling in your language, because that decides whether you have to notify or not.
What the Manufacturer Does So You Can Start Without Red Tape
Yanguas Professional formulates and manufactures in Tudela (Navarre), with ISO 9001 and ISO 22716 certified production, and its products are formulated under the European cosmetics regulation and notified on the CPNP. For distributors in other markets it coordinates the labelling, registrations and technical documentation each country requires, and it issues certificates of free sale when the destination is outside the EU.
On top of that comes what regulation does not cover: exclusive distribution by country under contract, gradual onboarding of products, technical training for your network and sales material adapted to your market.
💡 Before ordering your first shipment: ask the manufacturer for the list of products notified on the CPNP and check which languages its labelling already covers. It saves work and tells you whether you will have to notify anything yourself.
If you are still setting up the company, the first steps are in how to start a beauty distribution business. If you already distribute professional cosmetics in another EU country and want to add a Spanish hair care brand, tell us about your market and company type on the Yanguas Professional distributors page.
