The topic is short and compact
Most feedback loops arise because formula, packaging, advertising claims and documentation are decided one after the other, even though they are technically connected.
The safety report under Annex I of Regulation (EC) No 1223/2009 covers composition, stability, preservation and packaging material, so every late change affects all parts.
A packaging change after testing has begun usually restarts stability testing and the compatibility assessment; a formula change additionally restarts the 28-day preservative efficacy test.
Fixed approval checkpoints before each test run and an authorized decision-maker on the brand side prevent parallel workflows from turning into bottlenecks.
A brief with measurable targets, packaging type, and planned advertising claims brings forward decisions that would otherwise only be made in late sampling stages.
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Where do feedback loops occur in cosmetics development?
In development projects for makeup and skincare, five sources of loops recurringly occur. Each of them reopens a topic that was formally already completed.
Briefing loops: The concept is revised multiple times because, without a real formulation basis, it remains unclear which requirements can be met simultaneously, such as high coverage combined with a lightweight texture in a skin tint.
sampling loops: The first sample arrives late, and feedback from different departments comes in sequentially and is partly contradictory. Each piece of feedback generates a new sampling round.
Packaging loops: The packaging material is only selected after formulation approval. It then turns out that the viscosity does not suit the pump, a serum is insufficiently protected in the desired jar, or a stick cannot be filled into the barrel.
Claim loops: Advertising claims are only formulated during the artwork stage. If proof for a claim is missing, either the claim must be dropped or additional testing must be commissioned.
Documentation loops: Safety assessment, labeling, and notification take place at the end. Any necessary formulation change at this point entails new testing, a new INCI list, and new artwork.
What all five sources have in common is that a decision made in one place has consequences in another that only become visible later. Better status updates make these consequences visible, but do not prevent them.
Why are formulation, packaging, and documentation interconnected?
The dependencies are not organizational, but legally and technically based. According to Art. 10 of Regulation (EC) No 1223/2009, a safety assessment must be available prior to placing on the market and a cosmetic product safety report must be drawn up in accordance with Annex I. Annex I Part A requires, among other things, the quantitative and qualitative composition, the physical/chemical characteristics and stability, the microbiological quality including the results of the preservation challenge test, as well as the relevant characteristics of packaging material, in particular purity and stability.
The safety report is part of the product information file under Art. 11, which must remain available for ten years after the placing on the market of the last batch. According to Art. 19(1)(g), the list of ingredients belongs on the packaging, and during notification under Art. 13, the original labeling and a photograph of the packaging are submitted in addition to the formulation details.
For project planning, it follows that: formulation, packaging material, and label are not separate work packages, but input parameters of the same assessment. If one of them changes, the others change with it.
Late change | What it typically reopens |
|---|---|
Raw material or concentration in the formulation | Stability, preservation challenge test, safety report, INCI list, artwork, notification |
Packaging material or closure | skin compatibility with the formulation, stability in the final container, packaging material details in the safety report, filling |
New advertising claim | Evidence and, if applicable, additional tests, product information file, artwork |
Additional color shade of a range | Pigment proportion and dispersion, sample, stability, labeling |
Which tests make late changes expensive?
Late changes become expensive primarily due to fixed-duration tests that must be restarted after the modification. In the preservative efficacy test, the product is inoculated with defined microorganisms and monitored over 28 days, as described in a review paper on the preservation of cosmetic products. The effectiveness of a preservative system depends on the formulation: on the pH value, on water activity, and on interactions with other ingredients. For example, parabens are ineffective in alkaline formulations, and talc can significantly reduce the antimicrobial activity of methylparaben.
The same study shows that the packaging also influences preservation. Open jars and bottles are more susceptible to microbial contamination during use than closed systems with an airless pump, and packaging materials can reduce the effectiveness of preservatives through migration or adsorption. Switching from an airless dispenser to a jar is therefore not merely a matter of design.
In addition, there is the skin compatibility between formulation and packaging. Additives in plastic packaging are not firmly bound to the polymer matrix and can migrate from the container into the product, as demonstrated by a study on extractables and leachables from cosmetic packaging. The extent of this migration also depends on the contents: in the same study, liquid simulants such as ethanol, glycerin, and paraffin oil leached phthalates from the packaging material. A stability test is therefore only reliable in the final packaging. If the packaging is replaced after the test has started, the test usually has to be restarted.
The article on stability and safety testing for cosmetics describes which tests must be completed before the launch.
How does an actual formulation base prevent briefing loops?
Briefing loops occur when requirements are formulated abstractly: "light, but covering", "rich, but non-greasy". Such pairs can only be weighed against each other on the product itself. If development starts on a tested formulation or on a benchmark product, the requirements are described as a deviation from a real baseline rather than as a wish list.
What a robust briefing defines
Product format and area of application, such as leave-on or rinse-off, eye area or lips, because these determine the requirements for raw materials and safety assessments.
Measurable target values such as viscosity range, pH range, coverage, or wear time on the skin instead of adjectives.
For complexion products like foundation or concealer, the number of shades and the undertone logic, because each shade requires its own pigment proportions and its own samples.
The packaging type, such as airless dispenser, tube, dropper, jar, or stick, and the fill volume.
The planned marketing claims and excluded raw materials.
Target price and volume, because both constrain the choice of raw materials and packaging.
A briefing covering these points brings forward decisions that would otherwise not be made until the third round of sampling. Why physical samples make sense even before budget approval is shown in the article Samples before budget approval.
What do early physical samples change about the coordination process?
As long as no sample is available, discussions revolve around concept papers, and each department envisions a different product. A physical sample makes texture, sensory profile, shade, fragrance, and application immediately evaluable. Many change requests from the concept phase disappear because they arose from uncertainty about the actual product experience.
The decisive factor is how feedback is collected. Loops occur when product management, marketing, and executive leadership evaluate a sample one after the other and each piece of feedback is sent individually to the lab. More effective is one evaluation round per sample with fixed criteria—such as spreadability, absorption rate, coverage, color fidelity, and fragrance—and one person who consolidates the feedback and resolves conflicting requests before passing them on.
Labtree is a B2B cosmetics developer and cosmetics manufacturer with its own laboratory in Germany, covering formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production. The process is divided into conceptualization, sampling, customization, prototyping, and production. The starting point is more than 1,000 proprietary formulations. Samples of pre-qualified formulations typically leave the sample warehouse within 24 hours, and standard sample shipping is free of charge. During customization, consolidated feedback is translated into formulation adjustments; in prototyping, packaging and design run parallel to product development. White-label products with standard packaging are usually ready for delivery in 2 to 3 months, while new private-label developments typically take 3 to 6 months. Key determining factors are the availability of raw materials and packaging supplies, as well as the completion of stability testing. The detailed process is described on the page Have cosmetics developed.
Which topics should run in parallel to the formulation?
Parallel does not mean completed at the same time, but started early. A topic is opened as soon as its input parameters are available in a robust preliminary version, and it is closed before a test with a fixed duration starts.
Topic | Reasonable start | Loop in case of late start |
|---|---|---|
Packaging selection and skin compatibility | with the first approved sample | Stability testing in the wrong container, restart of the test |
Fillability | before the prototype | Viscosity or pouring temperature do not match the equipment or container |
Advertising claims and evidence | in the briefing | missing evidence, additional testing, or deleted claims |
Safety assessment and product information file | preparatory during customization | Anomalies only after formulation approval |
Artwork and labeling | draft early, finalization based on formulation status | new INCI list after print approval |
The following applies to advertising claims: According to the Technical document on cosmetic claims, which explains the common criteria of Regulation (EU) No. 655/2013, explicit and implicit claims must be supported by adequate and verifiable evidence. The responsible person determines the methodology for providing evidence and justifies the evidence, where necessary, in the product information file. Anyone transferring an effect of the raw material to the finished product needs separate proof, such as the presence of the ingredient in an effective concentration. If the formulation changes, the responsible person must also ensure that the evidence remains valid. If the claim is only determined during artwork, this evidence is often missing precisely when the tests are already underway.
Notification is made via the European Commission's Cosmetic Products Notification Portal (CPNP); further national notification within the EU is not necessary. Because the original label and packaging photo are part of the notification, it belongs at the end of a chain whose links must be established beforehand. What else launch dates depend on is described in the article Avoiding launch delays in cosmetics development.
Parallel planning shifts decisions forward. If decision-making authority is lacking on the brand side, parallel work streams become waiting points, and the loop is created elsewhere. Four organizational prerequisites apply in practice:
One authorized decision-maker per project who consolidates feedback and approves samples, rather than distributing approvals across multiple levels.
Fixed approval points before each testing phase with lead time: formulation status before the start of stability testing and challenge testing, packaging materials before storage in the final container, INCI list before print approval.
A shared database for formulation status, packaging specifications, claims, and testing status, so that all parties involved see the same status.
An early clarification of the role of the responsible person: According to the Regulation, the manufacturer is whoever places a product on the market under their own name or trademark (Art. 2(1)(d)), meaning the brand in the case of contract manufacturing. It is therefore the responsible person and can transfer this role to the contract manufacturer by written mandate pursuant to Art. 4(3) of Regulation (EC) No 1223/2009. Clarifying this question only shortly before notification pushes documentation to the end.
Digital tools help with the shared database, but do not change the sequence of decisions. What project software can achieve in this context is discussed in the article Digital project management in cosmetics development.
Even with parallel planning, loops that lie outside the process logic remain. They cannot be planned away, but they can be taken into account in the schedule.
Test results that force an adjustment: If an emulsion shows phase separation in the stability test or a formulation does not pass the preservative challenge test, it must be adjusted and tested again.
Raw material and packaging bottlenecks: If a raw material is temporarily unavailable, an alternative must be evaluated, which in turn requires samples and tests.
Regulatory changes: The Scientific Committee on Consumer Safety (SCCS) evaluates ingredients according to its Notes of Guidance for the Testing of Cosmetic Ingredients and Their Safety Evaluation. After consulting the SCCS, the Commission may amend Annexes II to VI, i.e., set new prohibitions, maximum concentrations, or warnings (Art. 31 of Regulation (EC) No 1223/2009). If a project is running with an affected ingredient, a formulation adjustment is the result.
Strategic changes on the brand side: If the target group, price point, or positioning changes fundamentally, a restart is part of reality.
The realistic goal is therefore not zero loops, but a reduction to those loops that are objectively justified. Time buffers belong to tests with fixed runtimes and packaging procurement, not lumped together at the end of the project.
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FAQ
How many sample rounds are common in cosmetics development?
There is no fixed number. If a tested formula is adapted under White Label, a few rounds are often enough; for a new development under Private Label or a color range with many shades, there are more. The deciding factors are the clarity of the briefing and whether feedback arrives bundled or piece by piece.
When should the packaging be finalized?
At the latest before stability testing in the final container begins. It makes sense to start the selection with the first approved sample, so that compatibility and fillability can be tested early.
Does stability testing have to be repeated after a packaging change?
As a rule, yes, if the material, closure or contact surface changes, because interactions between formula and packaging can affect the result. Whether an existing test can be transferred is assessed case by case by the safety assessor.
Who decides what evidence an advertising claim requires?
The responsible person defines the methodology for substantiation and keeps the evidence available in the product information file. That is why the planned claims should already be in the briefing, so that the necessary tests can run in parallel with development.
Which current regulatory change often leads to new artwork loops?
Regulation (EU) 2023/1545 extends the list of fragrance allergens that must be labeled. Products newly placed on the market since July 31, 2026 must comply, and products already available by July 31, 2028. For fragranced products, the fragrance supplier's allergen list should therefore be available before the artwork draft.
Does project management software help against feedback loops?
It helps when everyone involved sees the same status of formula, packaging and testing. It does not change the order of decisions. The Labtree article Digital Project Management in Cosmetics Development goes into this in more detail.
How long does cosmetics development take with parallel planning?
It is not possible to give a flat-rate duration. The timeframe is determined by tests with fixed durations, such as the 28-day preservative challenge test and the stability test in the final packaging, as well as the availability of raw materials and packaging. Parallel planning primarily reduces the waiting times between these steps, not the tests themselves.
