SOSOO Amenities — Resources
CPNP — the Cosmetic Products Notification Portal — is the EU's mandatory pre-market registration system for cosmetic products. Every cosmetic product placed on the EU market must be notified on the CPNP before it goes on sale. This includes hotel shampoo. This includes body lotion. This includes every amenity product in your guest bathrooms.
Most hotels assume their supplier has handled this. Many suppliers have not — at least not for every product in their range, and not for every custom-labelled variant supplied to individual properties.
Check your amenity programme's compliance status with SOSOO.
The CPNP is the notification system established by EU Cosmetic Regulation (EC) No 1223/2009, Article 13. It has been mandatory since 2013. The portal is maintained by the European Commission and accessible to national authorities across all EU member states.
Notification is not a certification — it does not mean the product has been tested or approved by a regulatory body. It means the product's formulation, safety documentation, and labelling information are on file with the EU authority. What it creates is a clear legal record of who placed what on the market and whether the documentation existed at the time.
For enforcement purposes, that record matters.
Every product notified on the CPNP must be linked to a Responsible Person (RP) — the legal entity that takes on regulatory responsibility for placing the product on the EU market. The RP must be established in the EU.
For hotel amenities, the RP is almost always the amenity supplier. But the legal structure of the relationship determines this, not assumption.
If your property operates under a supply agreement where the supplier provides products under your hotel's branding, you could find yourself legally positioned as the RP depending on how the contract is written. This happens more often than people realise with custom-branded hotel programmes — and it means you carry direct liability for any unregistered product.
Before signing any supply contract for custom-branded amenities: confirm in writing who holds the Responsible Person designation for each product. Get the CPNP notification number. If the supplier cannot provide it, that product should not be in your bathrooms.
A CPNP notification is not a form. It is a documentation package. The Responsible Person must hold — and make available on request to national authorities — the full product information file (PIF) for each registered product.
The PIF includes the product's full INCI composition with concentrations, the cosmetic product safety report (CPSR) signed by a qualified safety assessor, a stability study and microbiological testing including an ISO 11930 preservative efficacy challenge test, manufacturing method documentation, and evidence of labelling compliance under Regulation (EC) No 1223/2009.
The notification on the CPNP portal itself requires the product name, function, countries where it is marketed, and confirmation that the safety assessment exists.
None of this is quick to put together for the first time. A properly registered product represents weeks of preparation before it can legally go on the market.
Many mid-market amenity suppliers in Spain and across Europe source formulations from third-party manufacturers. The manufacturer may hold CPNP registration for their base formulation. When the supplier applies a custom label — even if the formula is unchanged — that creates a new notifiable product. The custom-labelled version may or may not be separately registered.
When a hotel requests custom branding — their logo, their name, their colour — this almost always creates a product that needs its own CPNP notification. If the supplier has not processed that registration, the product cannot legally be placed on the EU market.
This is not a hypothetical risk. Inspections under EU Cosmetic Regulation are ongoing across member states. Unregistered products can be ordered off the market. The Responsible Person carries the enforcement exposure.
The simplest test is direct. Ask your supplier for the CPNP notification number for each product they supply to your property — not a category, not a base formulation, the specific product as you receive it.
A supplier who has handled this properly will provide notification numbers within 24 hours. A supplier who cannot, or who gives you a notification number for a base product while supplying a custom-labelled variant, is giving you incomplete compliance coverage.
Three questions worth asking now:
Can you provide the CPNP notification number for each product as supplied to our property? Who holds the Responsible Person designation for each product? Does custom branding change the notification status?
If any of these produce hesitation or vague answers, treat that as your compliance assessment.
CPNP registration is part of every SOSOO programme — completed before any product goes into a guest bathroom, not retrospectively. Every product SOSOO supplies carries a notification number linked to a product information file that is current, complete, and accessible.
The formulations SOSOO develops are registered as they are supplied — not as base formulations with separate custom-labelled variants. The documentation reflects what is actually in the room.
For properties that need to verify their current compliance status, SOSOO can review the documentation your current supplier has provided and identify gaps. Start that conversation here.
Who is the Responsible Person for my hotel's amenities? Usually your supplier, if the supply contract is structured correctly. If products carry your hotel's brand, confirm in writing that the supplier holds the RP designation and can show CPNP notification for each specific product — not just the base formulation.
What happens if a product in my bathrooms is not CPNP-registered? The product is not legally compliant on the EU market. National authorities can order it removed. The Responsible Person faces enforcement action. If your contract places you in the RP role, that exposure is yours.
Does CPNP registration expire? The notification does not expire automatically, but if the formulation changes — preservative levels, fragrance, active ingredient concentration — the product information file must be updated and a new safety assessment completed. An unchanged product with a current PIF remains valid.
Does a Spanish-manufactured product still need CPNP registration? Yes. CPNP notification is required for every cosmetic product placed on the EU market regardless of where it is manufactured.
Can I search the CPNP to check whether a product is registered? The CPNP is not a public database. You verify compliance by requesting the notification number from the Responsible Person. If they cannot provide it, the product may not be registered.
How long does CPNP registration take for a new formulation? With a complete product information file — safety assessment, stability study, ISO 11930 test, INCI documentation — the notification on the CPNP portal itself takes a day. Getting the PIF to that state takes 4 to 8 weeks, depending on whether the formulation is new or built on a certified base.
Get in touch
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