The topic is short and compact
A project tool makes status and approvals visible, but it does not shorten stability testing or preservative challenge testing.
The product information file and CPNP notification require complete, easily accessible documentation anyway; it may be stored electronically or in another format.
If the packaging material is only chosen after formulation approval, stability and challenge testing may, in case of doubt, have to start all over again.
Formulation version, sample, test status, and batch release should be clearly linked in a single system, with a clearly designated responsible person.
Digitization saves time when dealing with version conflicts, approval latency, transferring INCI lists to artwork, and shade ranges in makeup.
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What does digital project management mean in cosmetics development?
This usually refers to a portal or a shared work environment in which milestones, tasks, sample statuses, approvals, and documents of a development project are centrally stored. Typical functions include milestone tracking along conception, sampling, customization, prototyping, and production, a versioned document archive, comment and approval functions, and the batch history.
Part of this digitization is not an optional extra, but stems from the law. According to Article 11(1) and (3) of Regulation (EC) No 1223/2009, the product information file must be kept for ten years after the last batch was placed on the market and made readily accessible to the authority in electronic or other format. The notification pursuant to Article 13(1) is carried out electronically prior to placing on the market. For this purpose, the European Commission operates the free Cosmetic Product Notification Portal (CPNP), which, in addition to the responsible persons, is also accessed by the competent authorities and poison control centres.
Digital project management is therefore built on documentation that must be complete, versioned, and retrievable anyway. The question is whether the tool also structures the path there or merely archives the result.
How do cosmetics manufacturers digitize their processes?
For cosmetics manufacturers, digitalization generally affects four areas: formulation and specification management, batch documentation, sample and approval management, and regulatory documentation. The benefits in each case are tangible, as are the limitations.
Area | What is mapped digitally | Limitation |
|---|---|---|
Formulation and specification | Formulation versions, INCI list, target values for pH, viscosity, and color | Does not replace laboratory testing to verify whether a change alters stability or texture |
Batch documentation | Manufacturing records, in-process controls, batch release, traceability | Only as good as the data recorded at the vessel and filling line |
Samples and approvals | Which formulation version is in which sample, who approved it and when | Texture, sensory profile, and color shade are evaluated on the physical sample, not on screen |
Regulatory affairs | Product Information File, safety report, stability data, CPNP status | The assessment itself remains the expert work of the safety assessor |
For batch documentation, Good Manufacturing Practice is the standard. According to Art. 8(2) of the Regulation, compliance is presumed where manufacturing takes place in accordance with the relevant harmonized standards, the references of which have been published in the Official Journal; as such, the Commission lists EN ISO 22716:2007 in its list of harmonized standards for cosmetic products. ISO 22716 is therefore neither mandatory nor proof, but establishes this presumption. A digital batch system facilitates implementation, but does not replace the production processes it is intended to reflect.
Why does a tool not reduce development time?
Because the critical path of cosmetics development consists of physical tests and dependent decisions, not communication. A status visible in real time does not change the fact that stability testing takes weeks and can only begin once the formulation and packaging materials are finalized.
Stability tests have fixed durations. An accelerated protocol described in the literature stores samples at 8, 25, and 40 °C, as well as at 40 °C and 75% relative humidity over 30 days, testing after 24 and 48 hours as well as after 7, 15, and 30 days for parameters including pH value, conductivity, viscosity, and phase separation after centrifugation (Mahmood and Akhtar, Stability study of a multiple cosmetic emulsion). Such time frames can be planned, but they cannot be shortened by software.
Packaging is part of the test. The preservative challenge test is performed in the original packaging whenever possible because the container affects the concentration and efficacy of the preservative; lipophilic preservatives are more likely to be absorbed by the container material (Halla et al., Review on cosmetics preservation). The safety assessment report also requires, according to Annex I Part A of the Regulation, information on stability under reasonably foreseeable storage conditions and on the relevant characteristics of the packaging material, in particular purity and stability.
This results in the typical loss of time: if the packaging is only selected after final formulation release—such as switching from a jar to an airless dispenser or from glass to a plastic tube—stability and preservative testing may well have to start over from scratch. A project tool will indicate this loop, but cannot prevent it.
Where does digital control actually save time?
A tool saves time where projects wait for information instead of test results. This primarily affects four situations:
Version conflicts: When it is unclear which formulation version is in stability testing and which is in the latest sample, incorrect approvals occur. A clear mapping of sample, formulation version, and test status prevents this.
Approval latency: Approvals of samples, artwork, or specifications that sit in inboxes for days extend the project schedule without any technical reason. Fixed approval steps with designated responsible parties shorten these waiting times.
Artwork and labeling: If the INCI list is adopted from the approved formulation instead of being typed out manually, the risk of discrepancies between formulation and label—which often only get noticed during print approval—decreases.
Shade ranges in makeup: In a foundation or concealer range, each shade has its own pigment proportions, its own target color values, and its own samples. Without a shared database, shade approvals, shade names, and batches are easily mixed up, especially when multiple shades are being readjusted in parallel.
Added to this is post-production: A complete batch history with raw material batches and in-process values makes it traceable why a subsequent batch deviates in color or viscosity. This protects deliverability, but does not accelerate the initial launch.
What really determines time-to-market?
Time-to-market depends primarily on how early three things are determined: a realistically feasible formulation base, a physical sample, and the packaging material. The later one of these is decided, the more tests run sequentially instead of in parallel.
Formulation base instead of open-ended development. If a project starts from an existing, already tested formulation, the work begins with adjusting the texture, color, or active ingredient content rather than the basic formulation. Above all, this shortens the number of sampling rounds.
Early physical samples. Texture, payoff, coverage, and sensory profile can only be assessed on the sample. Decisions made on the sample are more reliable than agreements based on descriptions and benchmark photos.
Packaging material and manufacturability in parallel. If the packaging material is determined in parallel with the formulation adjustment, stability testing can start directly in the final packaging. The same applies to manufacturability: the pouring temperature and cooling profile for sticks or the filling behavior of a low-viscosity foundation help determine whether a formulation that works in the laboratory also holds up in production.
As a B2B cosmetics developer and cosmetics manufacturer based in Hamburg with its own laboratory, Labtree operates according to this logic: formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production are all under one roof. The starting point is market-ready, tested Labtree formulations; standard samples of pre-qualified formulations are usually dispatched free of charge from the sample warehouse within 24 hours. White-label products with standard packaging are typically ready for delivery in 2 to 3 months, while private-label new developments usually take 3 to 6 months to reach market readiness. The detailed process is described on the page Having cosmetics developed, while the article Realistic timelines in cosmetics development outlines which factors affect the timeline.
What data should brands and manufacturers manage together?
All data on which a release depends should be managed jointly. In practice, this includes:
Formulation version with INCI list and change history
Specification with target values and tolerances, such as pH value, viscosity, color values per shade
Stability status per formulation version and packaging material, including test plan and interim results
Result of the preservation challenge test in the final packaging
Artwork status and labeling
Status of safety report, product information file, and CPNP notification
Batch releases and production deviations
The division of roles is important. Under the regulation, the manufacturer is whoever places the product on the market under their own name or trademark—in the case of contract manufacturing, that means the brand. It is the responsible person under Art. 4 and can transfer this role to the contract manufacturer by written mandate. Whoever holds the role must ensure the safety assessment before placing the product on the market pursuant to Art. 10(1) and keep the product information file readily accessible pursuant to Art. 11. A shared system should therefore clearly show who creates, reviews, and archives which document. What these documents contain is explained in the article EU Cosmetics Regulation in Practice, and the scope of testing before launch in the article Stability and Safety Testing for Cosmetics.
Whether a manufacturer truly has control over their processes is evident less from the interface of a portal than from concrete answers. These questions can be asked right in the initial conversation:
Can the manufacturer state the exact formulation version for every sample?
When is the packaging material determined, and is stability testing carried out in the final packaging?
Is manufacturability tested in the laboratory before the formulation is approved, or only with the first production batch?
How are approvals documented, and who is authorized to give approval?
Can raw material batches be traced back to the finished batch?
If these answers remain vague, a good tool merely shifts the bottlenecks to a more visible place. The article Reducing feedback loops in cosmetics development describes how queries and revision rounds can be structurally reduced.
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FAQ
Does the product information file have to be kept digitally?
No. Regulation (EC) No 1223/2009 requires that the product information file be kept for ten years after the last batch is placed on the market and made readily accessible to the authority in electronic or other format. Digital, version-controlled storage facilitates this, especially with formulation changes over several years.
Who registers a cosmetic product in the CPNP, the brand or the contract manufacturer?
The notification is made by the responsible person prior to placing the product on the market. In the case of contract manufacturing, this is the brand, which can delegate this role to the manufacturer by written mandate. The processes are described in the article "EU Cosmetics Regulation in Practice" in Labtree Magazine.
Which software do cosmetics manufacturers use for formulations and batches?
Usually a combination of formulation and specification management, an ERP system with batch tracking, and document management for product information files and safety reports. For brands, the product itself is less critical than the question of whether the formulation version, sample, and test status are clearly linked.
Does a customer portal replace sample approvals?
No. Texture, sensory profile, opacity, and shade can only be assessed on a physical sample. A portal helps clearly assign sample feedback to a formulation version and record approvals in a traceable manner.
Can AI accelerate formulation development?
Computational models can help to estimate the properties of ingredients or formulations at an early stage and pre-sort variants. However, stability testing, preservative efficacy testing in the final packaging, and sample evaluation remain physical tasks with fixed timelines. As a rule, the greater leverage lies in an existing formulation base and early-defined packaging materials.
How long does development take until the first production batch?
This primarily depends on the model: An adapted white-label formulation with standard packaging is ready for delivery much sooner than a newly developed private-label product that requires entirely new stability data. Decisions on packaging made late, repeated stability testing, and raw material availability can push back the timeline. For details, see the article “Cosmetics Development: Realistic Timelines”.
Which documents should you request when changing manufacturers?
The INCI list, specifications, stability data, safety report, and batch history are important, insofar as you are contractually entitled to them. With white label, the formulation remains with the manufacturer; with private label, formulation rights depend on the contractual agreement. The process is described in the article "Changing Cosmetic Manufacturers".
