Today’s consumers want more from their cosmetic products than simply new formulations. They’re looking for a personalized experience, to feel that what they’re using meets their individual needs and that it’s tailored and relevant to them. This means creating products that are customized to diverse individual factors such as age, lifestyle, climate, gender, ethnicity, geography and health and wellbeing.

Innovation in device development is enabling this shift, revolutionizing the beauty regime and creating a new ecosystem of products that allow an individual’s physical attributes to be measured, monitored and enhanced on a continuous cycle.

With this comes challenges. Whilst manufacturers must comply with the relevant regulations around the world, existing legislation often lags behind current trends and may not explicitly address personalized beauty products.

In Europe, for example, cosmetics manufacturers and suppliers must comply with Cosmetics Regulation (EC) No. 1223/2009, which outlines the ingredient restrictions and labelling requirements, as well as the safety standards that cosmetic products must fulfil before being placed on the EU market.

Some cosmetics will be prepared in situ, for example using a dispenser at the retailer’s store. In such situations, the device becomes the “manufacturing facility” and therefore needs to comply with Good Manufacturing Practices (Article 8). The Responsible Person (RP) – the manufacturer or other legal or natural person based in the EU that guarantees product compliance – therefore needs to ensure that the device is regularly calibrated and standardized to ensure consistent dispensing volumes, that it is kept in a good hygienic condition, and that people using the device are properly trained.

Further, any products being placed on the EU market, must undergo a safety assessment. This can pose a significant challenge for the RP if the exact product composition of all possible combinations of ingredients cannot be planned in advance. The timeframe is manageable if the product is being shipped to the customer. However if the product is being blended at the retailer’s store whilst the customer waits, a good IT tool to perform the safety assessment might be the solution.

Two further challenges center on customized formulations and product labels. If either the ingredient composition, the label or both are customized, then separate Product Information Files (Article 11) and CPNP (Cosmetic Products Notification Portal) notification (Article 13) need to be made for each customized product.

The best solutions for clients and personal care organizations are created when they work with a multi-disciplined team of scientists, engineers, designers and regulatory experts. This enables proactive and collaborative challenge from the start and a more iterative and efficient way to progress and solve a project.

“The market is now about more than chemistry and cosmetics,” says Matt Herd, VP Consumer, Sagentia. “Diagnostics, devices and customized formulations are taking center stage, delivering real value to the customer as well as the brand through a more personalized engagement. A collaborative and multi-disciplinary approach is seeing the big brands and the challenger organizations compete and win customers on a more level playing field.”

“Fulfilling regulatory obligations for customized cosmetic formulations can be a challenge,” adds Dr Helena Eixarch, Project Manager – Cosmetics, TSG Consulting. “The real strength lies in TSG and Sagentia working together. By considering the regulatory aspects from the start, we can help customers develop an effective strategy, helping them bring compliant products to market faster.”

TSG and Sagentia will be exhibiting at in-cosmetics North America, held on 17-18 October 2018 in New York (Booth A74).

Dr Helena Eixarch will be speaking in the Technical Seminars Theatre (18 October, 10:10 – 10:40) on the ‘EU cosmetics regulation – A guide to exporting cosmetics to the EU’.