How to test and approve cosmetics in 5 steps

Which different types of cosmetics are there?

Before I started working at SkinConsult, I always thought that the only purpose of using cosmetics was to make oneself more beautiful. For me, this was hair gel – for my sisters this was mascara.

It wasn’t until I really dived into the world of cosmetics that I realized cosmetics are much bigger, and really used by everyone, everywhere, all the time. In addition to make-up, there are also personal care, oral care and so on. All cosmetic products.

Once, I decided to count how many cosmetic products I use every day. I ended up with 11 products, so quite a bit more than just my hair gel!

This can also be seen in the definition of cosmetics, which reads:

• Any substance or mixture used on the skin, hairs, or in the oral cavity,
• …with a view to cleaning (shower gel)
• …perfuming them (fragrance)
• …changing their appearance (make-up)
• …or protecting them (sunscreen)
• …or keeping them in good condition (body lotion)
• …or correcting body odours (deodorant).

Does the type of cosmetic product matter for its safety?

From a safety point of view, the type of cosmetic also matters. The main distinction between all types of cosmetics is how the products are used. Think about whether the product is rinsed off or not, which part of the body you put it on, whether you spread it, stick it on or spray it on, and so on.

You can both apply a body lotion and a shower gel all over your body, but leave one on while you rinse off the other. You can imagine the body lotion you leave on stays on your body longer and must also be safer than the shower gel you rinse off after a few seconds.

Or the difference between a face cream and a hand cream; the skin on your face is thinner and more sensitive than the somewhat thicker (calloused) skin on your hands.

This means with facial lotions, more sensitive skin must be taken into account. Similarly, products for oral care or for more intimate, private parts must be developed with the greatest care.

Where can you test cosmetic products?

Developing cosmetics is quite a complex process. The product must be safe and do what it’s supposed to do. A sunscreen must of course be safe, so that you do not get any irritation, but it must also have the right sun protection factor (SPF).

And maybe even more: moisturizing, anti-aging…?

These are such niche questions, with the result that there are several companies involved in the process of developing a product. For example, a product formulator at a factory is very good at putting together the perfect cream that feels silky smooth.

A safety assessor, on the other hand, is good at checking the safety of the cream.

Perhaps the brand owner also wants the product to have an anti-aging claim, and outsources a claim substantiation test of the cream by volunteers to demonstrate the effect.

The product must be resistant to bacteria and fungi, so a microbial laboratory must test this.

All companies at a glance:

• Responsible Person: the company that takes final responsibility for the product. Can be a separate company, or one of the following companies (as long as this company has its physical address within the EU)
• Brand owner: the company that will sell the product under its brand name
• Importer: a company that imports cosmetics from outside the EU into the EU
• Distributor: a company that helps sell cosmetics in more areas and countries
• Manufacturer: the company that develops and manufactures the cosmetic product
• Safety assessor: the company that checks the safety of cosmetic products
• Microbial laboratory: control of bacteria and fungi
• Stability laboratory: checks how long product shelf life is
• Analytical laboratory: analyzes the product for specific impurities such as mercury, lead and other heavy metals
• Claims / efficacy testers: ensure claims such as SPF are well supported
• Raw material and packaging suppliers: they supply the ingredients a manufacturer needs to make a cosmetic product

How to create a PIF?

A Product Information File (PIF) is the complete passport of a cosmetic product.

It consists of 3 parts:

• The safety assessment (CPSR)
• The product notification to the EU web portal (CPNP)
• Administrative information about the product

So the PIF is actually a framework that encompasses these components, making it easy both to create one and for the competent authorities to easily reach the right information. The administrative section mainly contains information about:

• Who is responsible for the product, and which companies are involved?
• What information is made available to the consumer (not only the artwork and product labelling, but also advertising brochures, TV commercials, e-commerce, etc.)?
• How does the product work, and what is the substantiation for its claims?

This information is sometimes quite similar to the information that a safety assessor needs to make a CPSR. As a rule of thumb you can say that a full PIF contains all the information, and a CPSR only contains the information necessary to approve the safety of a product.

For example, SPF tests are necessary for the safety assessor so that consumers do not suffer sun damage, while an anti-aging claim has little to do with safety. This also means that a safety assessor is not mandatory for the administrative file.

Some companies therefore choose to make the PIF themselves and only have the CPSR made by a safety assessor. On the other hand, this is often double work for all companies involved, because a lot of information then has to be gathered, reviewed and processed twice.

What does it cost to test cosmetics?

Many different tests may be required to develop a product properly and safely. This depends on the complexity of a formula, but also on any claims on the label.

In general: the more and stronger the claims, the more testing needs to be done. Tests can have a short or long duration, affecting their price.

Cosmetics tests can also be simple, to be carried out in a laboratory, or a bit more difficult because people (volunteers) and doctors such as dermatologists are needed.

For example, having a sunscreen tested can easily cost a few thousand euros purely for demonstrating the SPF on volunteers, while this is not necessary for a simple soap.

And if a manufacturer already has a ready-made recipe, compared with if a formula has to be developed completely from scratch, it will of course save a lot of development time and costs.

How to have your cosmetics tested and approved in 5 steps

To put cosmetic products on the market safely, you will have to follow a number of steps. We list them for you below.

Step 1 – manufacture or outsource

Make the choice: produce yourself or outsource production to a manufacturer.

Step 2 – develop a concept formulation

Create a concept formula and have it checked by a safety assessor

Step 3 – have products tested and make adjustments

Use stability tests and microbial tests to determine shelf life. If necessary, make some adjustments to the formula so that the product has a good shelf life (and have the safety assessor look at the adjustments). This allows the safety assessor to complete the CPSR.

Stap 4 – substantiate claims

Test any other claims you would like to make, such as your cosmetics being anti-aging. This completes the administrative part of the PIF.

Stap 5 – CPNP notification

Notify your product to the CPNP. With this, your product is ready for market.

How to test creams?

Creams are quite difficult products to create. Such a formula is a combination of water and oil. As you probably already know, oil and water don’t mix well. So there are other ingredients (emulsifiers) that have to keep things together.

Difficult, also because a cream must be able to stand on the shelf for years without falling apart. A good stability test is essential, so that you are swiftly able to see any stability issues like whether the product is going to separate.

Or becomes very thin and runny over time, so that the product starts leaking out of the bottle.

A cream should also feel good on your skin. You can do this yourself, or ask a test panel to do this.

Creams contain water, which also makes them attractive to bacteria and fungi. A good challenge test, which checks whether the product has been properly preserved, is essential.

And how about testing soaps?

Soap is used to clean your hands, your feet and the rest of your body. The standard soap often does this based on its pH, which is the degree of acidity. A low pH is acidic, a high pH is basic.

Soaps are usually basic, with a pH between 8 and 10. Bacteria and fungi cannot handle this well and die, which is why soap works.

You can imagine that a soap should not get too high of a pH, because it can also have harmful effects on the skin. But the other way around is also not good, if the pH becomes more neutral and therefore has no effect on bacteria and fungi.

So it is very useful for soaps to test how their pH changes over time (hopefully the pH doesn’t change).