The Cosmetic Products Regulation stipulates in Article 13 that the responsible person shall transmit the information relating to the cosmetic product in electronic format, prior to placing it on the market. The type of information that is required is listed in this article https://www.chemicalsconsulting.eu/2018/07/16/notifica-di-prodotti-cosmetici/ .
The notification is generated and transmitted via the European CPNP portal which is accessed after creating an account in SAAS.
In some cases it may be necessary for the distributor (not identified as the person responsible for that product) to send a notification.
The cases and methods in which this happens are clarified in article 13.3 of the regulation:
a distributor who makes a cosmetic product already placed on the market in another Member State available in one Member State and translates, on its own initiative, any element of the label of the product in question in order to comply with national law, shall submit the following information in electronic format: (a) the category of the cosmetic product, its name in the Member State of dispatch and its name in the Member State where the product was made available, in order to allow its specific identification; b) the Member State in which the cosmetic product is made available; c) your name and address; d) the name and address of the responsible person from whom the product information documentation is immediately available.
In cases where the cosmetic is produced by one company and marketed by another, it is not always easy to understand who has to send the notification or how to allow your customer to be in compliance without having to provide sensitive information.