Notifying a balm: how the UK, EU, Canadian and Australian systems work

A field by field walk through the UK SCPN and EU CPNP submissions, plus Canada's notification form and AICIS registration, with timings, fees and rejection causes.

Notification is the last administrative step before a balm can be sold, and first-time makers misread it in the same two ways: as an approval, and as something that can wait until orders arrive. It is neither, and in the EU and the UK it has to be complete before the first tin changes hands. This page walks the actual fields of each system.

• EU: Article 13, before first supply
• GB SCPN: free, pre-market
• Canada CNF: within 10 days of first sale
• AICIS year: 1 September to 31 August
• No UFI on a finished cosmetic

Notification is not approval, and it comes first

Nobody reads your submission before it is accepted. There is no reviewer, no queue and no certificate. The portal stores what you typed, issues a reference number, and makes the data available to competent authorities, market surveillance officers and poison centres. That is the whole function. A reference proves you filed, not that anyone approved your formula, and it is no substitute for the safety report described under safety assessment and the CPSR.

The timing turns on what "placing on the market" means. Regulation (EC) No 1223/2009 defines making available on the market as supply for distribution, consumption or use in the course of a commercial activity, "whether in return for payment or free of charge", and placing on the market as the first making available. Samples, market stall testers, gifting and a box left with a shop on sale or return all count. The sequence is therefore: freeze the formula, get the safety report signed, finish the artwork, notify, sell. Notifying after the first market day is a breach even if everything else is right, as noted under selling at markets and online.

Great Britain: the SCPN service, field by field

SCPN stands for Submit Cosmetic Product Notification, a GOV.UK service run by the Office for Product Safety and Standards. It replaced CPNP for the Great Britain market after the UK left the EU regime. Northern Ireland stayed on CPNP.

Account setup is a one-off. You need a Government Gateway user ID for the business, then you register the responsible person: legal name, the establishment address that will appear on the label, and a contact. That address must be a real establishment in the UK, not a forwarding service, because it is where the product information file has to be available for inspection. A UK maker with no EU responsible person cannot notify to CPNP, and vice versa, which is the structural point made under selling balms in the UK and EU.

Then, per product:

1. Product name and category. Every name the product is sold under, plus a three-level category from a fixed taxonomy inherited from the EU list. The category drives which further questions you are asked, and lip products sit apart from skin care.
2. Special category flags. Whether the product is intended for children under three, and whether it is for external intimate hygiene. Both raise the evidential bar sharply, and a children's balm is a formulation decision as much as a paperwork one.
3. Responsible person and contact. Prefilled from your account, plus a named physical person for poison centres to telephone. Not a shared inbox: a person.
4. Country of origin. Required for imported product. If you make it yourself in the UK, this is the UK.
5. Formulation. Either a frame formulation chosen from the standard list, or exact concentrations. See the next section for which one you are allowed.
6. pH. Declared where the product is below 3 or above 10. An anhydrous balm has no meaningful pH, and the honest answer is to say so rather than to invent a figure from a wetted strip.
7. Nanomaterials. Presence, identification, particle size and specification, and the reasonably foreseeable exposure conditions. This catches makers using nano grades of zinc oxide or certain mica and pearl pigments without noticing the grade.
8. CMR substances. Presence of any substance classified carcinogenic, mutagenic or toxic for reproduction in category 1A, 1B or 2, named with its CAS or EC number.
9. Label and packaging images. Legible images of the original labelling and a photograph of the packaging. This is the field that catches people out: the artwork has to be finished before you notify, not after.

You get a reference number on submission. Keep it with the batch paperwork described under batch records, because it is the fastest thing to produce when a trading standards officer asks.

The EU: CPNP, and who is allowed to submit

CPNP is the Cosmetic Products Notification Portal, a Commission database reached through an EU Login account. Its content is set by Article 13 of Regulation (EC) No 1223/2009 and is close to identical to SCPN: category and name, the responsible person and where the product information file is kept, country of origin for imports, the member states of availability, a physical contact person, nanomaterials, CMR substances in categories 1A, 1B and 2, and the frame formulation for poison centres.

The part that trips small brands is not the fields but the roles. CPNP recognises two, and they do different jobs.

• Responsible person. One notification per product, before placing on the market. Manufacture in the EU and sell under your own name and you are it. Import finished balms and you are it, unless a manufacturer outside the EU has appointed someone else by written mandate. Importing does not lighten the obligation, it moves all of it onto you.
• Distributor. A distributor who makes a product already on one member state's market available in another, and translates any element of the labelling to do so, notifies under Article 13(3) with a reduced dataset: the category, the name in the originating member state and in the destination, the destination member state, and their own identity. This is not a second product notification and it does not replace the responsible person's.

One notification covers one product. Shade and scent variants of one base are usually separate products because the composition differs, which is where a wide range gets expensive in exactly the way the safety report does.

Frame formulations, and when exact percentages are required

A frame formulation is a standard template of ingredient categories with concentration ranges, drawn up so a poison centre can act on a call at three in the morning without your full recipe. You pick the one matching your product type and the portal accepts it in place of the formula. Most balms and salves fit comfortably, because a skin care frame formulation handles oils, waxes, butters and fragrance.

Two things narrow that option. First, the frame formulation has to actually describe the product: if any ingredient falls outside the ranges the template allows, you cannot use it and must give exact figures. Second, both portals require exact concentrations for defined substances of concern within the frame formulation, which in practice means anything restricted in Annex III, anything classified CMR, and anything present as a nanomaterial. A menthol or camphor balm at the top of its permitted range therefore ends up declaring the exact percentage whichever route you take, which is one reason the limits under menthol and camphor safety limits are worth knowing before you formulate rather than after.

The portals also treat products for children under three and products for external intimate hygiene as higher risk and ask for more exact information. The precise rule sits in the current CPNP and SCPN user manuals rather than in the regulation, and it has been revised more than once, so read the manual for the service you are using rather than a summary of it.

Poison centres: why a balm has no UFI

Anyone who has read about chemical compliance in Europe has met the UFI, the sixteen-character Unique Formula Identifier printed on cleaning products and adhesives, and the poison centre notification behind it. Both come from Article 45 and Annex VIII of the CLP Regulation, Regulation (EC) No 1272/2008, which makes importers and downstream users placing hazardous mixtures on the market submit harmonised information to appointed bodies and print the UFI on the label.

Finished cosmetics are outside that system. CLP Article 1(5) excludes cosmetic products in the finished state and intended for the final user from those provisions, because a separate regime already covers them. That separate regime is the frame formulation you filed with CPNP or SCPN, which is precisely the poison centre channel for cosmetics. So a balm needs no UFI, no PCN dossier and no appointed body submission.

The trap runs the other way. Raw materials you buy are not finished cosmetics. A fragrance concentrate, a solvent, or a classified essential oil arrives with a safety data sheet and may carry its own UFI, belonging to the supplier's mixture. That identifier is theirs, it describes their product, and it must never be copied onto your label. What you should be extracting from those documents is composition data for allergen declaration and for your own dossier, as argued under sourcing ingredients and fragrance allergen labelling.

Canada: ten days after the first sale, in ranges

Canada inverts the timing and simplifies the content. Section 30 of the Cosmetic Regulations requires the manufacturer and the importer to notify the Minister not later than ten days after the day on which the sale of the cosmetic begins in Canada. Notification is post-market: you may sell first and file within the following ten days, the opposite of the European position, which catches people carrying a compliance routine in either direction.

The Cosmetic Notification Form is free and submitted to Health Canada's Cosmetics Program. It asks for the product name and brand, the product form and its function, the name and address of the manufacturer and of the importer, the address of the site of manufacture, and the full ingredient list.

The concentration column is the interesting part, because Canada accepts ranges. You give either an exact percentage or one of the form's bands, and for a balm the bands are almost always sufficient.

Two Canadian points that are not on the form but decide whether the form is worth filing. The Cosmetic Ingredient Hotlist is an administrative list, not a regulation: it names substances Health Canada considers may not comply with the general prohibition in the Food and Drugs Act, and an ingredient on it will draw a letter even though nothing in the Hotlist itself has the force of law. And changes to notified information are notifiable on the same short clock, so a reformulation or a change of importer is a fresh filing, not a private matter. Bilingual labelling and metric net quantity are separate obligations, set out under Canadian cosmetic labelling.

Australia: you register the business, not the product

Australia does not have a cosmetic product notification portal at all, which is why searching for one produces nothing. Under the Industrial Chemicals Act 2019, in force since 1 July 2020, cosmetic ingredients are industrial chemicals and are administered by AICIS, the Australian Industrial Chemicals Introduction Scheme, which replaced NICNAS. The obligation attaches to the introducer, meaning whoever imports or manufactures, and it has two limbs.

Registration. If you introduce industrial chemicals for commercial purposes above a low value threshold, you register your business for each registration year, which runs from 1 September to 31 August. Registration sits at one of three levels set by the value of your introductions in the relevant year, with the boundaries at 500,000 and 5 million Australian dollars, and the fee rises with the level. The threshold and the fees are set in the charges legislation and indexed, so read the current schedule rather than a figure in an article.

Categorisation. Separately, every chemical you introduce falls into a category: listed, exempted, reported, assessed, or commercial evaluation. Most balm ingredients, including beeswax, shea butter and common carrier oils, are on the Australian Inventory of Industrial Chemicals and are therefore listed introductions. Exempted and reported introductions carry their own conditions, a pre-introduction report in the reported case, and an annual declaration covering the previous registration year. Records are kept for five years.

Two consequences for a small maker. Importing a finished balm makes you the introducer of every chemical in it, so an ingredient list you never had to think about becomes an inventory-checking exercise. And AICIS says nothing about labelling or claims: the ingredient list on the pack comes from the Cosmetics Information Standard 2020 enforced by the ACCC, covered under Australian cosmetic labelling, and a therapeutic claim moves the product to the TGA entirely, the line drawn under cosmetic versus drug claims.

What actually goes wrong

Because nothing is reviewed, submissions are rarely rejected in the sense of being sent back. A defect instead sits undetected until an inspection, a complaint or a customs check surfaces it, which is worse. These are the recurring ones.

Keeping a notification current

A notification is a living record. Anything changing the identity or composition of the product is a reason to update it: an ingredient swap, a supplier change that alters a grade, a percentage change, new artwork, a new responsible person, a new market, discontinuation. The EU and GB systems let you amend an existing record rather than file afresh, which is why the reference number belongs in your batch documentation and not in an email folder.

Treat the notification as the last step of a formula freeze rather than an afterthought. Changing a formula already means revisiting the safety report, the ingredient list and possibly the allergen declarations. Adding the notification to that checklist costs nothing and removes the commonest failure above. The wider launch sequence is under starting a balm business.

What this page cannot decide for you

Three limits, stated plainly. This site cannot submit a notification on your behalf, cannot check your entries, and cannot tell you whether the frame formulation you picked is the right one for your specific formula, because that turns on the exact composition and on the current version of the portal's own guidance. Nothing here is legal advice.

Two boundaries are worth naming. Jurisdiction: everything above applies to the EU, Great Britain, Northern Ireland, Canada and Australia as described, and nowhere else. The United States runs a different system again, facility registration and product listing under MoCRA rather than notification, set out under MoCRA duties and US cosmetic labelling. And currency: portals revise their forms far more often than legislatures revise regulations, so a field list tells you what to prepare, not what you will see on screen. Open the current user manual before you submit, and check the label you are about to photograph against reading a balm label, so that the artwork you file is the artwork you ship.

Reviewed and updated 6 September 2026. Spotted an error? Tell us and we will fix and log it.