How to project a cosmetic product…with special attention to its compliance.

2020-09-16T22:10:43+02:00 September 16th, 2020|Pratical tips, Regulations|0 Comments

The compliance of a cosmetic product is a fundamental aspect for placing it on the market: here are the 6 main steps to follow in the design of a new cosmetic product to comply with the requirements of Regulation (EC) no. 1223/2009.

1. Identify the type of product

First of all you need to understand what type of product to produce, based on your target market and budget.

2. Create the formulation and choose suppliers

Once the type of product has been established, you need to create its formula; the choice of raw materials must be made on the basis of the functionality, color, consistency, and scents which you want to achieve. To have a high quality and compliant product, it is essential to find suppliers who are able to offer not only quality raw materials but also the documents necessary for the compliance procedure.

3. Verification of the formulation and laboratory tests

After defining the formulation, begins the phase of confrontation with a Safety Assessor (mandatory according to Regulation (EC) 1223/2009) to verify the safety of a cosmetic product before it is placed on the market. The safety assessor will ascertain the conformity of the ingredients used, it will be also based on the results of the mandatory and optional laboratory tests. This step guarantees the consumer the safety of the finished product, which must be free of all those potentially toxic or harmful substances at topical level.

4. Compliance of packaging

The packaging of a cosmetic product is of fundamental importance: it is the first interface with the consumer but also with the authorities for checking the conformity of the product.

The lack of information or unclear and misleading information and the incorrect use of claims are examples of violations of Regulation (EC) 1223/2009 and Regulation 655/2013 respectively. The penalties are very variable and depend on the type of violation, from different severity of fines up to the withdrawal of the product. To see how to make compliant cosmetic labels, read our delicate article.

5. PIF processing

All product information must be reported in the document known as the Product Information File (PIF). The PIF differs from the Cosmetic Dossier required by the previous legislation (Directive 76/768 / CE) in many respects; in particular, it must report the toxicological evaluation, to define the safety of the cosmetic for human health. The PIF must be readily accessible and stored for 10 years after the last batch of the product has been placed on the market; it must also be prepared by a Safety Assessor with suitable qualifications following a format specified by current legislation. In case of a not compliance PIF, there could be penalties from € 10,000 to € 100,000.

6. Company and product registration the CPNP portal

Before placing a cosmetic product on the EU market, it is mandatory, according to Regulation (EC) no. 1223/2009, the notification to the European portal CPNP (Cosmetic Products Notification Portal).
The electronic notification is divided into a series of information regarding the product, including the complete formula and the presence of nanomaterials or CMR substances. It also includes the data of the Responsible Person and the loading of the labels with which the product is marketed.

Do you want to be sure that your cosmetic product is compliant? Contact us, we will check it together!