Your EU notification goes up in the importer's name
What stops a Korean brand at the EU border is rarely the paperwork volume. The CPNP notification is free and finishes the day the dossier is ready, but only an EU-established Responsible Person can file it, and by default that is the importer. Homosalate is capped at 7.34% face-only in the EU against 10% in Korea.
CPNP notification carries no fee, is filed electronically and involves no approval review. The constraint is the Responsible Person: only an EU-established entity can file, and when the importer takes that role, the label name and the PIF address become the importer's. On the formula side homosalate is the usual blocker, capped at 7.34% for face products in the EU against Korea's 10%.
The filing is the easy part
The EU is not hard because of document volume. A CPNP notification costs nothing, goes in electronically, and produces a reference number the same day once the dossier exists. No authority reviews it and no certificate comes back, so a quotation with a line item for "obtaining EU certification" is charging for a step that does not exist.
One condition hangs off that simplicity. Only an EU-established Responsible Person may file, and a product without one cannot be placed on the market at all. Article 4 of Regulation 1223/2009 requires a manufacturer outside the EU to appoint that person by written mandate, and it makes each importer the Responsible Person for the units it brings in. A Korean factory or head office cannot hold the role.
By default, the importer holds it
This is where the commercial terms are decided. When a European buyer offers to "handle the notification," it usually means that buyer becomes the Responsible Person — and Article 19 then puts its name and address on the container and the packaging, alongside the country of origin for an imported product.
Switching distributor later means filing again and reprinting the label. The Product Information File lives at the Responsible Person's label address and must be kept for ten years after the last batch was placed on the market, so raw material specifications, stability reports and claim substantiation all sit in the other company's records. Unless the brand intends to go exclusive with one distributor, appointing a third-party RP service that the brand itself contracts is cheaper over a few years than unwinding the arrangement.
A CPSR is not a human-application test report
The first document most Korean brands offer is a human-application test report. That evidence supports efficacy claims; the Cosmetic Product Safety Report the EU requires is something else. Part A collects ingredient toxicology profiles and exposure estimates, and Part B is the assessment itself, signed by someone qualified in pharmacy, medicine or toxicology.
That signature is also why RP providers ask for the full file before they sign a mandate. The Responsible Person carries legal liability for the product, so gaps in raw material specifications, stability data, packaging specifications or claim evidence stop the deal rather than delay it. Comparing offers on a monthly RP fee alone misses where the calendar actually goes.
What changed in the formula on 1 May
A formula cleared in Korea routinely needs a second pass for the EU, and UV filters are the usual place it shows up.
| Filter | Korea limit | EU limit |
|---|---|---|
| Homosalate | 10% | 7.34%, face products only |
| Ethylhexyl methoxycinnamate | 7.5% | 10% |
| Octocrylene | 10% | 10%, 9% in propellant sprays |
| 4-Methylbenzylidene camphor | 4% | Prohibited |
A body sunscreen built on homosalate at 10% cannot travel. 4-MBC was banned by a 2024 regulation and left the EU market on 1 May 2026. Omnibus VIII, Regulation (EU) 2026/78, applied from the same date: it moved nano silver and non-micronised silver onto the prohibited list, and added concentration and product-category limits for hexyl salicylate and o-phenylphenol.
Nanomaterials stretch the schedule further. Article 16 requires products containing a nanomaterial to be notified six months before being placed on the market. For a sunscreen using nano titanium dioxide or zinc oxide, the planning date is six months ahead of the shipment, not the filing day.
One EU label does not exist
The ingredient list is written once, in INCI. Four other particulars are not: nominal content, the date of minimum durability or period-after-opening, precautions for use, and the product function follow the language law of the Member State where the product is made available. Selling into Germany, France and Spain means those four fields appear in three languages.
Claim wording catches Korean packaging just as often. "Paraben-free" and similar phrasing denigrates a legally permitted ingredient and is not accepted under the EU claims framework, and "hypoallergenic" must not be written so that it reads as a guarantee against an allergic reaction. Both are reprints, so they belong in the cost sheet early.
In short
- CPNP notification is free and immediate. The time goes into appointing an EU Responsible Person and completing the Product Information File first.
- If the importer is the Responsible Person, the label name and the PIF address are theirs. Where a distributor change is plausible, price a third-party RP first.
- Homosalate at 10%, any nanomaterial, and "paraben-free" copy each mean an EU-specific formula or an EU-specific pack.
- Nanomaterial products notify six months ahead. Count back from the shipping date, not the sampling date.
Which ingredients are moving right now is on today's ingredient signal, and category price bands and cost structure sit in the product planner.
*Sources: Regulation (EC) No 1223/2009, consolidated text applicable 1 May 2026, Articles 4, 11, 13, 16 and 19 — EUR-Lex / Regulation (EU) 2026/78 (Omnibus VIII), applicable 1 May 2026 / UV filter limits by country, 2026 — janeyoomd.com / EU technical document on cosmetic claims, "free from" and "hypoallergenic" annexes, summarised — ceway.eu*
Questions people ask
There is no approval or certification step. An EU-established Responsible Person files an electronic notification in the CPNP, a reference number issues, and that is the end of it. The work sits before the filing, in the Product Information File and the safety report it contains.
No. Article 4 of Regulation 1223/2009 requires a non-EU manufacturer to designate an EU-established Responsible Person by written mandate, and makes each importer the Responsible Person for what it places on the market. Both the filing and the name printed on the label belong to that EU entity.
Changing distributor means a fresh notification and a new print run for the label. The Product Information File is kept at the Responsible Person's address shown on the label and must be held for ten years after the last batch, so the source documents sit with the other company.
They are different documents. Human-application testing supports efficacy claims, while the CPSR gathers ingredient toxicology and exposure in Part A and carries a qualified assessor's signature in Part B. This is why an RP service asks for the file before it will sign the mandate.
Start with the UV filters. Homosalate is limited to 7.34% in face products, which catches body sunscreens designed to Korea's 10% ceiling, and 4-methylbenzylidene camphor left the EU market on 1 May 2026. Any nanomaterial in the formula adds a notification six months before launch.