Cosmetics formulation and compliance: the complete guide

Cosmetics share a lot with supplements — they are formulated products of many ingredients, with costs, labels, and compliance — but they live under an entirely different regulatory world. No nutrition, no NRVs; instead INCI naming, safety assessments, product information files, fragrance-allergen rules, and notification systems. For a manufacturer moving into cosmetics, or a cosmetics maker leaving spreadsheets behind, this guide covers the cosmetic-specific landscape and how software manages it.

Cosmetics are a different regulatory world

The first thing to understand is that cosmetics are not supplements with different ingredients — they are governed by their own framework entirely. There is no nutrition panel, no nutrient reference values, no health claims in the supplement sense. Instead there is INCI ingredient naming, a safety assessment regime, a product information file, restricted-substance rules, and notification. The formulation mechanics are familiar; the compliance layer is wholly different.

A platform that serves cosmetics applies the cosmetic rules — not nutrition logic — while keeping the familiar formula management underneath.

Two axes: form and type

Cosmetics formulation is shaped by two independent axes. The form drives how you formulate — an emulsion (cream, lotion) has an oil phase, a water phase, and an emulsifier; an aqueous gel is water-based with a gelling agent; a surfactant system (shampoo, wash) is built on surfactants with foam and viscosity logic; an anhydrous product (balm, butter, stick) has an oil or wax base and no water. The type or use drives compliance. Understanding both axes is key to formulating cosmetics correctly.

INCI naming

Cosmetic ingredients are declared by their INCI names — a standardised international nomenclature — in a specific order on the label. Getting the INCI list right, in the correct order, is fundamental to a compliant cosmetic label. Software that holds the INCI name for each ingredient and generates the list from the formula produces the declaration correctly, the way the cosmetic label requires.

The Product Information File and the CPSR

In the EU, every cosmetic must have a Product Information File (PIF) — a dossier of information about the product — including a Cosmetic Product Safety Report (CPSR), the safety assessment by a qualified assessor. These are the backbone of cosmetic compliance: the documented evidence that the product is safe and properly characterised. A system that holds the formula and its data feeds the information these documents require.

Fragrance allergens and restricted substances

Cosmetics carry specific rules for fragrance allergens — a defined list (recently expanded) of substances that must be declared when present above thresholds — and for restricted substances with limits on use. Managing the fragrance system and checking restricted substances against their limits is a cosmetic-specific compliance task that software handles by holding these rules as data and checking the formula against them.

Notification: CPNP and beyond

Before a cosmetic is placed on the EU market, it must be notified through the CPNP (the EU's cosmetic product notification portal), with a responsible person designated. Other markets have their own notification and registration systems. As with supplements, the notification layer is a practical step to plan for, distinct from the formulation and safety work.

MoCRA: the US cosmetic regime

The US has its own cosmetic framework under MoCRA, bringing requirements around facility registration, product listing, a responsible person, and cosmetic GMP. For a brand selling cosmetics in both the EU and the US, the two regimes differ — a clear parallel to the supplement world, and another reason to manage market-specific rules from one formula. Sunscreen is the sharpest example: a cosmetic in the EU but an over-the-counter drug in the US, an entirely different regime for the same product.

Nutricosmetics: where the worlds meet

Beauty-from-within products — ingestible beauty supplements — sit between the two worlds: formulated and regulated as supplements, but positioned for beauty. A platform that handles both supplements and cosmetics is well-placed for this growing category, applying supplement rules to the ingestible product while understanding its beauty positioning.

The takeaway

Cosmetics are formulated like supplements but governed by a wholly different framework — INCI naming, the PIF and CPSR safety assessment, fragrance-allergen and restricted-substance rules, CPNP notification in the EU, MoCRA in the US — with form driving formulation and type driving compliance. Software that applies the cosmetic rules while keeping familiar formula management lets a manufacturer formulate cosmetics compliantly, across markets, from one system. Different world, same need for control.

Lemoniq handles cosmetics with their own rules — INCI, PIF/CPSR data, fragrance allergens, and per-market compliance — alongside supplements in one platform. See what Lemoniq can do for your cosmetics