Any distributor marketing products under their own name or brand in Portugal is considered the “responsible person” and must notify their products via the Cosmetic Products Notification Portal (CPNP).
Under Portuguese law, a “Distributor” is defined as a commercial intermediary who makes a product available within the European Union without being the manufacturer or importer.
Notification via the CPNP:
A mandatory requirement for distributors, if a product is marketed under their own brand or modified in a way that may affect its compliance with regulatory requirements, they acquire the status of responsible person and must submit a notification via the CPNP, in addition to appointing a designated responsible person (technical expert).
However, if a distributor merely translates the labelling independently to comply with Portuguese legislation, only a simplified notification is required, with no need for a designated responsible person.
Registration with INFARMED and Tax Obligations
Any company making the first commercial sale of cosmetic products in Portugal must register with INFARMED through the following platforms:
- SRE COS (Cosmetic Entities Register), and
- SRCT (Fees and Billing Management).
The first commercial sale of cosmetic products on national territory corresponds to their initial placement on the domestic market, regardless of whether the product is already marketed in Portugal. In other words, entities introducing cosmetic products from abroad, or domestic entities manufacturing cosmetics for market placement, must register on both platforms mentioned above.
Moreover, the marketing of cosmetics in Portugal is subject to a monthly fee of 1% of sales volume (excluding VAT). Companies must submit a monthly sales declaration detailing invoices and credit notes.
It is important to note that retailers purchasing products already marketed by other distributors or manufacturers are not required to register on these platforms.
However, if these retailers place a cosmetic product on the Portuguese market for the first time, they are considered distributors and must register on the relevant INFARMED platforms and submit the monthly sales declaration.
Unlike other sectors, cosmetics do not require prior authorization from INFARMED to be marketed. The authority only intervenes for market supervision, ensuring that products comply with regulations and do not pose health risks.
Furthermore, there is no public register of cosmetic products in Portugal, as the official database — the Cosmetic Products Notification Portal (CPNP) — is managed by the European Commission.
Belzuz Abogados, S.L.P. – Branch in Portugal has extensive experience in all procedures necessary to ensure compliance with legal obligations concerning the marketing of cosmetic products in Portugal.