The topic is short and compact
Hybrid makeup, the skinification of body care, and microbiome care with understated claims can be achieved by 2026 if stability and substantiation are planned early on.
For body lotion, the maximum limit for vitamin A is 0.05% retinol equivalent instead of 0.3% in other products; facial formulas cannot be directly applied.
Clean beauty is not a regulated term; according to the Commission's guidance document, "free from parabens" has been considered denigrating and unacceptable since July 1, 2019.
The effect of a raw material does not automatically apply to the final product; separate proof is required, such as the effective concentration in the formulation.
Products placed on the market after July 31, 2026, require the extended labeling of fragrance allergens in accordance with Regulation (EU) 2023/1545.
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White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
Which 2026 cosmetics trends can be implemented?
A trend is feasible when three conditions are met simultaneously: the formulation remains stable under reasonably foreseeable storage conditions, the planned advertising claim can be substantiated on the finished product, and all substances used are within the limits set out in the annexes of Regulation (EC) No 1223/2009. The overview summarizes the assessment for the key trend topics.
Trend | Technical bottleneck | Regulatory point | Assessment |
|---|---|---|---|
Hybrid makeup (skin tint, concealer, lipstick with caring active ingredients) | Pigment dispersion and active ingredient influence each other | Care claim must apply to the final product | easily feasible with early substantiation planning |
Skinification of body care | Active ingredient stability in large containers, preservation | specific maximum concentrations for body lotion | easily feasible, redefine concentrations |
Microbiome-oriented care | Preservation and microbiome claim are in tension | no harmonized criteria for “microbiome-friendly” | feasible with restrained claims |
Clean beauty and free-from concepts | no technical definition | Free-from claims strictly limited since July 1, 2019 | high hype risk |
High-dose active ingredient combinations | Oxidation, pH conflicts, crystallization | Substantiability, partially maximum concentrations | high hype risk without stability data |
For the upper rows, the work lies primarily in the formulation. For the lower rows, the risk lies in the advertising claim: a product can be technically flawless and yet not be allowed to be advertised as specified in the marketing brief.
How much skincare can hybrid makeup handle?
Hybrid products are viable when makeup performance takes priority and the skincare benefit is planned as an additional, substantiated feature. A skin tint with hyaluronic acid, a concealer with peptides, or a lipstick with nourishing lipids must first achieve coverage, color fidelity, wear time on the skin, and fillability.
Typical formulation problems
Pigment wetting: Humectants and water-soluble active ingredients alter the wetting of surface-treated pigments. Possible consequences include viscosity drift and shade deviations between the laboratory sample and the production batch.
Film formation versus skin feel: Film formers for transfer resistance and nourishing oils work against each other. A higher proportion of skincare ingredients generally comes at the expense of wear time on the skin.
Shade ranges: Each shade of a foundation or concealer range has its own pigment load. An active ingredient that is stable in light shades should therefore be tested again in dark shades.
Hot-poured sticks: Pouring temperature and cooling profiles limit which temperature-sensitive active ingredients can be used in blush or foundation sticks in the first place.
From a regulatory perspective: A claim regarding an ingredient must not give the impression that the final product possesses the same properties if that is not the case (criterion of truthfulness in the Annex to Regulation (EU) No 655/2013). Anyone claiming "with skincare benefits" therefore needs substantiation on the finished complexion product, not just the raw material supplier's data sheet. For hybrids with sun protection, SPF determination on the finished product is also required; the specifics are described in the article on the tinted SPF serum.
What is skinification, and what does it mean for body care?
Skinification refers to the transfer of active ingredient concepts from facial care to other categories, especially body care: body serums and lotions with niacinamide, retinoids, peptides, or hyaluronic acid. For new body care brands in 2026, this is one of the most accessible trends because the active ingredients are established. However, a facial formulation cannot simply be transferred 1:1 to the body.
Different maximum concentrations for body lotion
The reason is the larger application area and thus higher exposure. Regulation (EU) 2024/996 limits Vitamin A (Retinol, Retinyl Acetate, Retinyl Palmitate) in body lotion to 0.05% retinol equivalent, and in other leave-on and rinse-off products to 0.3%. Products containing these substances bear the notice "Contains Vitamin A. Consider your daily intake before use". Since November 1, 2025, non-compliant products may no longer be placed on the market, and from May 1, 2027, they may no longer be made available. For alpha-arbutin, the same regulation sets 2% in facial cream and 0.5% in body lotion.
Packaging materials and preservation in large containers
Body care is filled into larger tubes, bottles, and pump dispensers and is used over weeks once opened. Oxidation-sensitive active ingredients such as retinoids then require low-air packaging materials or airless dispensers, and the preservation efficacy test must cover the longer period of use. The relevant characteristics of the packaging material, in particular purity and stability, are in any case required in the safety assessment according to Annex I Part A No. 4 of the Cosmetics Regulation. For body care, this means: stability testing is carried out in the final container, not in laboratory glassware.
What is proven when it comes to microbiome skincare?
Microbiome-oriented skincare is feasible as long as the claims remain at the cosmetic core: mild cleansing, pH management, and skin barrier support. A review in Skin Research and Technology (2026) assesses the study situation on microbiome-oriented cosmetics as preliminary: most clinical data come from small, short, often open-label studies, and there are no harmonized test criteria for “microbiome-friendly.”
Preservation remains mandatory
The most common misconception is equating microbiome skincare with dispensing with preservation. According to Annex I Part A No. 3 of the Cosmetics Regulation, the results of the preservation challenge test are part of the cosmetic safety report; in practice, testing is carried out according to ISO 11930. The same review refers to a four-week study indicating that standard preservatives in appropriate concentrations do not significantly alter the skin flora; the data base for this is narrow. By contrast, the use of live probiotics is limited by the need for preservation. According to the same review, postbiotics and inactivated bacteria are easier to incorporate into cosmetic formulations, but are also still considered exploratory; this calls for cautious claims.
Formulate claims cautiously
Without harmonized criteria, the brand must substantiate a claim such as “microbiome-friendly” with a study design it justifies itself. Claims regarding barrier, moisture, or skin compatibility, which can be tested on the finished product using established measurement methods, are easier to substantiate.
What evidence is required for efficacy claims?
Every advertising claim requires sufficient and verifiable evidence, whether it is made explicitly or implicitly. This follows from Article 20 of Regulation (EC) No 1223/2009 and the six common criteria of Regulation (EU) No 655/2013: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. For trend planning, this results in four working rules:
Determine the claim first: It dictates what evidence is required, whether a consumer perception test, instrumental measurement, or efficacy study on the finished product.
Prove the effective concentration: Anyone attributing the property of an ingredient to the end product must substantiate it, for example, by demonstrating an effective concentration in the product.
Do not extrapolate beyond the data: Depictions of efficacy must not go beyond what the available evidence supports.
Do not present matter-of-course facts as special features: Properties that similar products also possess must not be claimed as unique, and mere compliance with minimum legal requirements is not a product benefit.
Studies have their own lead times and costs. Therefore, they belong in the schedule before artwork approval: anyone who defines the claim only after package design risks having to reprint. Which phrasings are impermissible in the EU is summarized in the article on cosmetic claims in the EU.
Which trends are more likely to just be hype?
Hype risk is carried by trends that define themselves by the absence of substances or by maximum amounts of active ingredients rather than verifiable product performance.
Clean beauty without a definition: “Clean” is not a regulated term. As a brand's own exclusion list, for example free of silicones or mineral oil, the concept is technically feasible; as an advertising claim, it pushes the boundaries of free-from claims.
Free-from claims: The Technical document on cosmetic claims by the Working Group on Cosmetic Products is not legally binding, but serves as a guideline for Member States; its Annex III has been applicable since July 1, 2019. According to this, “free from parabens” is not acceptable because it denigrates an authorized group of substances. “Free from preservatives” is ruled out if an ingredient with a protective effect against microorganisms is contained, such as alcohol, unless a challenge test of the formulation without this ingredient shows that it does not contribute to protection, and “free from allergens” is inadmissible because an allergy risk can never be completely ruled out.
High-dose combinations of active ingredients: Multiple active ingredients with different pH optima, oxidation tendencies, or limited solubility in a formulation lead to color change, odor alteration, crystallization, or degradation of active ingredients. Without stability data in the final packaging, the risk of complaints increases.
Anti-aging with medical undertones: Claims must remain cosmetic. Terms such as “repairs” or “heals” quickly go beyond what a cosmetic study can substantiate.
Two regulatory changes affect trend products placed on the market from 2026 onwards, regardless of which trend they follow:
Fragrance allergens: Regulation (EU) 2023/1545 expands the list of allergenic fragrance substances that must be individually indicated in the list of ingredients if they exceed 0.001% in leave-on products and 0.01% in rinse-off products. Non-compliant products may only be placed on the market until July 31, 2026, and made available until July 31, 2028.
Synthetic polymer microparticles: Regulation (EU) 2023/2055 restricts microplastics under REACH, staggered by product category: from October 17, 2027, for rinse-off products, from October 17, 2029, for leave-on products and for fragrance encapsulation, and from October 17, 2035, for makeup, lip, and nail products, which must bear the statement "This product contains microplastics." between October 17, 2031, and October 16, 2035. Microbeads used for exfoliating, polishing, or cleaning are not covered by these transitional periods and have been restricted since October 17, 2023.
For planning purposes, this means: A formulation developed in 2026 should be reviewed against the legal situation at the launch and post-production dates, not against the status at project start. For fragrances, this primarily concerns artwork, as the INCI list is often approved months before the launch. For glitter effects, texture polymers, and encapsulated fragrances, it affects the choice of raw materials itself.
Testing follows the order in which risks become expensive: first evidence and claim, then stability and preservation, and finally quantity.
Check evidence: Is there published data on the mechanism of action, at what concentration was it collected, and is this concentration within Annexes III to VI?
Define the claim: The planned marketing claim determines the study design, budget, and timeline.
Test stability in the final packaging: Annex I Part A No. 2 requires data on stability under reasonably foreseeable storage conditions. Phase separation, viscosity, color, odor, pH value, and, where claimed, the active ingredient content are monitored.
Demonstrate preservation: Challenge test according to ISO 11930 with the final formulation.
Start with an initial batch: Validate market reaction before expanding the color range or size variants.
The full scope of testing is described in detail in the article on stability and safety testing, and the path from trend to a robust launch in the article on trend products.
How Labtree processes trend concepts
Labtree is a B2B cosmetics developer and cosmetics manufacturer from Hamburg with its own laboratory and production capacities in Germany. Trend concepts are pre-qualified technically, economically, and regulatorily during formulation development; from the concept, laboratory samples, a manufacturable formulation, and the finished product are created. Samples of pre-qualified formulations typically ship within 24 hours from the sample warehouse. White label is usually ready for delivery in 2 to 3 months with standard packaging, while private label typically takes 3 to 6 months to reach market readiness. The minimum order quantity is generally 1,500 units per product, depending on product type, fill size, and packaging. The process is described on the page having cosmetics developed.
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FAQ
What is skinification?
Skinification refers to the transfer of active ingredient concepts from facial care to other categories, such as body, hair, or scalp care. For brands, this means established active ingredients in new formats, but with specific concentrations, packaging materials, and stability tests. For body lotions, lower maximum concentrations apply to some active ingredients than for facial products.
Which body care concepts are realistic for new brands in 2026?
Body serums and lotions featuring established active ingredients such as niacinamide or hyaluronic acid in packaging that preserves well are easy to implement. Retinoid concepts are more complex because maximum concentration limits, warning labels, and oxidation-protected packaging must all be aligned. The magazine article "Launching trend products quickly and reliably" takes a deeper look at how trend products can be brought to market reliably.
Can a body lotion contain retinol?
Yes, but according to Regulation (EU) 2024/996, a maximum of 0.05% retinol equivalent, and the label must carry the mandatory vitamin A warning. As of November 1, 2025, non-compliant products may no longer be placed on the market, and as of May 1, 2027, they may no longer be made available on the market either. Existing formulations should therefore be reviewed now.
Is clean beauty a protected term?
No. Neither the Cosmetics Regulation nor Regulation (EU) No 655/2013 defines "clean". Brands can set their own exclusion list, but they must substantiate any claim derived from it and are not allowed to denigrate authorized substances.
What changes in 2026 for the labeling of fragrance allergens?
Under Regulation (EU) 2023/1545, numerous additional allergenic fragrances must be listed individually in the ingredients list, starting at 0.001% in leave-on and 0.01% in rinse-off products. Non-compliant products may only be placed on the market until July 31, 2026. For launches from August 2026 onwards, artwork must therefore already include the extended labeling.
Can a product be advertised as microbiome-friendly?
In principle, yes, if the claim is substantiated with sufficient and verifiable evidence on the finished product. There are currently no harmonized testing criteria for this, so the brand must substantiate its study design itself. Claims regarding the barrier or skin compatibility are easier to substantiate using established methods.
With what quantity can a trending product be tested?
At Labtree, the minimum order quantity is generally 1,500 units per product, depending on the product type, fill size, and packaging. For color ranges, it is recommended to start with a few shades, as each shade requires its own formulation work and filling. What determines minimum order quantities is explained in the magazine article “MOQ in Cosmetics Explained”.
