The topic is short and compact
The critical path includes formulation approval, packaging selection, testing, safety report, and labeling; only design, procurement, and documentation run in parallel.
Stability testing and preservative challenge testing only begin with an approved formulation in the final packaging; any subsequent change may trigger them anew.
Accelerated stability tests typically run for one, two, or three months at 37, 40, or 45 °C depending on the product type, while the preservative challenge test generally takes 28 days to complete.
For makeup ranges, having numerous shades, fragrance variations, and packaging types extends the project timeline, as stability testing must cover representative variants and every type of packaging.
CPNP notification is not an approval or a bottleneck; only products containing certain nanomaterials must be notified six months prior to being placed on the market.
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How long does it take to develop a cosmetic product?
The duration is determined by three factors: how far the initial formulation is from the target product, how many sampling rounds are required until approval, and whether the packaging material is available as standard goods or is custom-manufactured. The following overview classifies the two service models.
Model | Starting point | Typical duration at Labtree | What extends the duration |
|---|---|---|---|
White Label | Ready-made, tested formulation from the manufacturer, adapted in texture, fragrance, or color; the formulation remains with the manufacturer | Usually 2 to 3 months until delivery capability, with standard packaging | Adjustments that alter the tested base, as well as customized packaging materials |
Private Label | New development according to brand requirements; rights and exclusivity are regulated by contract | Typically 3 to 6 months to market readiness | Number of sampling rounds, new active ingredients, color ranges, late packaging decisions |
With White Label, part of the testing work has already been completed because the base formulation is known. However, any change that alters the composition of the formulation or its behavior in the packaging material reintroduces testing time into the project. Anyone weighing between the two models will find the distinction in the articles on White Label Cosmetics and Private Label Cosmetics.
Which steps determine the schedule?
The critical path includes the steps that can only begin once the previous one is completed. In a typical project, these are:
Briefing, formulation development, and formulation approval. Texture, sensory profile, shade, active ingredient concept, and target price are decided on physical samples. Every additional sampling round delays all subsequent steps.
Packaging material decision. Stability tests should run in packaging made of the exact same material as the subsequent sales packaging. As long as the packaging material remains undecided, reliable testing cannot start.
Stability testing and preservative challenge testing. Both run in parallel, both require the approved formulation, and both take weeks to months.
Safety assessment and product information file. The safety report relies on the test results and can only be finalized afterwards.
Labeling and artwork. The INCI list and shelf-life indications are only determined once the formulation and stability data are finalized; this is followed by print approval and printing.
CPNP notification, production, and batch release. Notification occurs prior to placing the product on the market; production requires the approved formulation and delivered packaging materials.
Design, packaging material procurement, and preparation of documentation can run in parallel. Anything that a modified formulation resets back to square one cannot run in parallel.
Why can't stability testing be shortened indefinitely?
Stability tests measure whether a product changes during storage, transport, and use. The Cosmetics Europe guideline on stability testing cites standard conditions for this: accelerated storage at 37, 40, or 45 °C over one, two, or three months, depending on the product type. There is no standard protocol for all products; temperature, duration, and criteria are determined by the manufacturer based on product type and experience.
What is tested
Color, odor, and appearance
pH value and viscosity
Weight loss, for instance due to evaporation through the packaging
Changes to the packaging itself, such as deformation, corrosion, or migration
Microbiological stability during use
Why the test cannot be arbitrarily compressed
Higher temperatures accelerate changes, but do not replace observation time. The same guideline recommends corroborating the forecast from accelerated testing with real-time observation of retention samples from production in the final packaging. In addition, there is the question of scale: early findings come from laboratory batches, more precise ones from batches manufactured with production-scale equipment. Emulsions, gels, and cast masses do not automatically behave in the production vessel as they do in a beaker, because shear, heating, and cooling profiles differ.
For products exposed to temperature fluctuations, freeze-thaw cycles are also included. They reveal crystallization, turbidity, phase separation in creams, or damage to tubes and labels more quickly than storage at a constant temperature. Which tests a product must complete before launch is explored in detail in the article Stability and safety testing for cosmetics.
How long does the preservative challenge test take?
The preservation efficacy test typically takes 28 days to perform. The product is artificially inoculated with microorganisms and counted at several time points; a review article on cosmetic preservation in Molecules describes evaluation after 7, 14, 21, and 28 days. In addition, there is preparation, evaluation, and possibly a re-test if the preservative system is insufficient.
The test is not a mere formality. According to the SCCS Notes of Guidance, it is mandatory for all products that can spoil or infect consumers under normal storage and use conditions. There is no legally mandated, standardized test method; the responsible person decides on the details of the test, and a widely used method is described by the ISO 11930 standard.
When a re-test threatens
Change in formulation after the test starts: Even a different emulsifier can alter the effectiveness of the preservative system. Nonionic surfactants can reduce the activity of some preservatives, while lipophilic preservatives migrate into the oil phase in oil-in-water emulsions.
Change of packaging material: The primary packaging material can adsorb preservatives or influence them through migration; the review paper cites the incompatibility of nylon with parabens as an example.
pH shift: Parabens lose their efficacy in alkaline formulations.
This results in a simple planning rule: The test should only start with the approved formulation in the intended packaging. An early start with an intermediate status only saves time if nothing changes afterward.
What does the EU Cosmetics Regulation require before launch?
There is no pre-market regulatory approval for cosmetics in the EU. Instead, Regulation (EC) No 1223/2009 requires the responsible person to fulfill certain obligations before placing a product on the market. Four of these are relevant to the schedule:
Safety assessment (Art. 10(1)): Prior to placing on the market, a safety report in accordance with Annex I must be available. Part A requires, among other things, information on stability under reasonably foreseeable storage conditions, the results of the preservative challenge test, and the purity and stability of the packaging material. No test results, no safety report.
Product information file (Art. 11): It is maintained once the product is placed on the market and kept for ten years after the last batch placed on the market.
CPNP notification (Art. 13): The responsible person submits the product electronically to the Commission before placing it on the market. The European Commission's Cosmetic Products Notification Portal is a free online notification system; an additional national notification within the EU is not necessary. The notification itself is therefore not a bottleneck, but the data it requires is, such as the formulation and labeling.
Labeling (Art. 19(1)(c)): For a minimum durability of more than 30 months, an indication of the date of minimum durability is not mandatory; instead, the period of time after opening for which the product is safe is indicated. The stability data determines which indication goes on the label, so the artwork depends on it as well.
A real lead time exists for nanomaterials that are not regulated as colorants, preservatives, or UV filters and are not otherwise restricted: According to Art. 16(3) of the Regulation, products containing such nanomaterials must additionally be notified via the nanomaterial module of the CPNP six months prior to placing on the market. Anyone planning to use such a material should factor this into the schedule early on. The process of notification, product information file, and safety report is described in the article EU Cosmetics Regulation in practice.
What extends project timelines for makeup lines and packaging?
For makeup, it is primarily the number of variants that extends the project duration. A foundation or concealer line with many shades, a blush in several colors, or a lip line with different finishes multiplies shade development, sampling, and coordination. The Cosmetics Europe stability guideline recommends testing at least the shades that represent the extremes of stability, and following up with others if these results are questionable. Fragrance variants are more critical than color shades in this regard, because fragrances are more likely to interact with the formulation.
Packaging as an independent time factor
If a product is offered in multiple packaging types, the guideline recommends testing each type; in the case of multiple sizes, the smallest container.
Depending on the packaging, testing in different orientations may be useful, such as upright, inverted, or on its side, for example with pump dispensers or tubes.
Custom-manufactured packaging requiring dedicated tooling generally has longer lead times than standard packaging and is therefore a common reason why a fully developed product waits for its filling date.
Applicators, wipers, and pumps co-determine the result for mascara, lip tints, or fluid complexion products and should be finalized before formulation approval.
With skincare, the focus shifts: here, emulsion stability, sensitive active ingredients, and skin compatibility with the packaging are typical reasons for additional rounds. A vitamin C serum or a retinol cream usually requires packaging that keeps out oxygen and light, and it is precisely this packaging that must undergo testing.
A project gains time not through shorter testing, but through fewer iterations and early decisions. Four decisions have proven their worth:
Start with a tested base, where the concept permits it. Samples of pre-qualified formulations are usually dispatched from Labtree's sample warehouse within 24 hours, allowing texture and color to be evaluated early on a real product.
Determine packaging materials in parallel with sampling and submit packaging material samples for testing early, so that stability and skin compatibility run in the final material.
Define release criteria before the first sampling round: viscosity range, shade, skin feel, target price. Without criteria, every round turns into a fundamental discussion.
Time internal approvals. If feedback on samples or artwork is pending for weeks, the advantage of parallel processes is lost.
Labtree is a B2B cosmetics developer and cosmetics manufacturer with its own laboratory and production facilities in Germany. Formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production are thus under a single responsibility: manufacturability is already tested during development and not only when scaling up to production scale. This does not shorten testing time, but it reduces the risk of setbacks if a laboratory sample behaves differently on a production scale. The article Avoiding launch delays in cosmetics development discusses what else can cause schedules to slip.
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FAQ
Who is the responsible person in contract manufacturing?
Within the meaning of Regulation (EC) No 1223/2009, the manufacturer is whoever places the product on the market under their own name or trademark; in the case of contract manufacturing, this is the brand. It is therefore the responsible person pursuant to Art. 4 and can transfer this role to the contract manufacturer by written mandate. Who assumes the role should be determined before the start of the project, as the safety report, product information file, and CPNP notification depend on it.
How long does the CPNP notification take?
The notification itself is an electronic process without an official review period and is free of charge. However, it requires the final formulation, labeling, and a designated responsible person. A lead time of six months only applies to products containing nanomaterials that are not regulated as colorants, preservatives, or UV filters.
Are accelerated stability tests sufficient for the launch?
Accelerated tests provide a forecast on the basis of which the safety report and shelf-life indication are prepared. Industry guidelines also recommend monitoring retention samples from production in the final packaging in real time. The more unusual the formulation or packaging is, the more important this confirmation becomes.
How long does it take to develop your own cosmetics brand?
Product development is only one part of it; brand building, packaging materials, artwork, and sales preparation run in parallel. With an adapted white-label formulation, the first product is usually available faster than with a completely new development. The journey from the idea to the first batch is described in the Labtree article “Starting a Cosmetics Brand”.
Who owns the formulation after development?
This depends on the service model. With White Label, the adapted standard formulation remains the property of Labtree. With Private Label, formulation rights or exclusivity can be contractually transferred to the brand; this should be settled before development begins, as it affects costs and future changes of manufacturer.
Does changing manufacturers extend the development time?
As a rule, yes, if equipment, process, or packaging materials change, because stability data from a different production scale cannot simply be transferred. Existing formulation documentation, test reports, and the product information file shorten the transition. The process is described in the Labtree article “Switching cosmetics manufacturers: How a structured transition works”.
