This page exists to say “this does not apply to you” where that is in fact the case.
Chemical compliance runs several parallel regimes, and the expensive mistake is rarely a neglected obligation. It is usually meeting an obligation you never had — or mistaking one regime for another.
The short answer
A finished cosmetic product covered by Regulation 1223/2009 is not generically a PCN product. Cosmetics are notified through CPNP — the Cosmetic Products Notification Portal. That is a separate system, with its own legal basis and its own recipient.
A PCN notification arises from Article 45 and Annex VIII of the CLP Regulation and applies to mixtures classified as hazardous that are placed on the EU market.
The two routes do not substitute for one another and are not each other’s equivalent
.Why that does not settle the matter
Because a company is not a product.
A cosmetics brand is a business, and a business very often holds more than finished cosmetics. In practice you will find:
- ancillary and workshop preparations — removers, degreasers, surface-preparation products, cleaners for tools and workstations,
- products intended for non-cosmetic use, sold alongside the cosmetic line,
- raw materials and semi-finished goods resold onward,
- disinfectants, which sit under yet another regime of their own,
- side lines that belong to the same brand commercially and to an entirely different category in regulatory terms.
Each of these is assessed individually, per product — never collectively because “it is a cosmetics company”. The same applies in reverse: a household-chemicals manufacturer that launches one cosmetic product follows the CPNP route for that one product.
How to settle it in practice
Three questions, in this order:
- Is this specific product placed on the market as a cosmetic product within the meaning of Regulation 1223/2009 — intended for contact with the external parts of the body in order to clean, perfume, change the appearance, protect, keep in good condition or correct body odours? If yes, the route is CPNP.
- If not — is this mixture classified as hazardous for health or physical effects? Only that triggers PCN and the UFI code.
- Independently of both — is a safety data sheet required? The Cosmetics Regulation does not exempt you from REACH, and a data sheet can be required where PCN does not apply .
What decides is the intended use and classification of the specific product, not the profile of the company and not the name on the label.
What ChemReady does not do
ChemReady does not handle CPNP notifications and does not maintain the product information file for a cosmetic product under Regulation 1223/2009. We do not act as the responsible person, we do not produce cosmetic product safety reports, and we do not notify products to CPNP.
If your product is a cosmetic, it is not a product for us — and we would rather say so here than after you have paid.
If, however, your portfolio contains mixtures outside the cosmetic regime, those we can carry: we read the composition and CLP classification from the safety data sheet you supply, generate the UFI code, and prepare the CLP label draft and the PCN dossier with a completeness check. You submit the notification yourself, from your own ECHA account.
FAQ
Do cosmetics require PCN and a UFI code? A finished cosmetic product under Regulation 1223/2009 is not generically a PCN product. It follows the CPNP route.
Does nail polish require PCN? Polish placed on the market as a cosmetic product — no, it goes to CPNP. But do not carry that conclusion across a whole portfolio: ancillary and non-cosmetic products are assessed separately.
What is the difference between CPNP and PCN? Different legal basis, different recipient, different data set. CPNP — Cosmetics Regulation 1223/2009. PCN — Article 45 and Annex VIII of CLP.
Does a cosmetic need a safety data sheet? Sometimes yes. The Cosmetics Regulation does not exempt you from REACH. That question is independent of PCN.
Check what is in your portfolio
If you are not sure which of your products sit on which side of this boundary, tell us what you make. We will answer before you buy anything.