The topic is short and compact
Fucoidan, phlorotannins, and MAAs are marine substance classes with no direct terrestrial counterparts; product efficacy can only be claimed once proven on the finished product.
Wild-harvested algae vary by species, location, season, and harvest year; an extract only becomes reliable through a batch specification with a reference substance.
Arsenic and iodine levels can be high in brown algae; certificates of analysis per batch should therefore be part of raw material release and trace assessment pursuant to Art. 17 of the Cosmetics Regulation.
An MAA-containing algae extract is not a permitted UV filter, as under Art. 14 of Regulation (EC) No. 1223/2009, only the filters listed in Annex VI may be used.
The purchase of a commercially available extract generally does not constitute utilization within the meaning of the Nagoya Regulation, whereas research on a marine organism you collected yourself often does.
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What distinguishes marine active ingredients from land-based ingredients?
Marine active ingredients originate from macroalgae (brown, red, and green algae), microalgae and cyanobacteria, marine animals and their by-products, or cultured marine organisms. The difference from land-based ingredients lies less in the "natural" label than in the chemistry. A review article on algal metabolites in cosmetics (Thiyagarasaiyar et al., 2020) describes fucoidan as a sulfated polysaccharide from brown algae, phlorotannins that can make up to 25 percent of the dry weight of brown algae, and mycosporine-like amino acids (MAAs) from the red alga Porphyra umbilicalis and from microalgae that absorb UV radiation.
Some marine raw materials have long been standard in formulations, just not as an active ingredient: according to the same review, more than 80 percent of agar comes from Gracilaria species, which are used for their stabilizing, thickening, and gelling properties. For formulation development, the first question is therefore what function the marine raw material should perform in the product:
Texturizer: Agar, alginates, and carrageenans as thickeners and gelling agents.
Active care ingredient: Extracts containing polysaccharides, polyphenols, or carotenoids such as fucoxanthin.
Physical effect: such as sponge spicules that produce a microneedle effect as spicules in serums.
Origin claim: an extract whose main contribution is positioning; the principles from the article on storytelling about raw material origin apply here.
Depending on the function, the specification, usage concentration, and substantiation requirements differ significantly. A thickener is approved based on viscosity and gel strength, while an active care ingredient is approved based on the content of a marker substance and data that support a claim on the finished product.
Why do algae extracts vary from batch to batch?
Wild-harvested algae change their composition with species, location, season, and harvest year. A two-year study on three brown algae from the Irish west coast (Garcia-Vaquero et al., 2021) found significant differences by species, season, and year for all examined chemical and phytochemical parameters, fatty acids, and minerals. Protein content ranged between 2 and 11 percent, with peak values in winter or spring and lowest values in summer or autumn. A review on macroalgae in topical formulations (Bogdan et al., 2025) adds that solvents, temperature, and extraction process conditions alter the quantity and quality of extracted metabolites, citing fluctuating phlorotannin levels as the cause of inconsistent efficacy from batch to batch. Differences between genera alone are substantial: Ulva can contain up to 65 percent polysaccharides in dry matter.
For raw material release, this means: the INCI designation of an algae extract reveals little about its content. A raw material only becomes reliable through a specification that the supplier verifies for each batch.
Raw material source | Main drivers of variation | What the specification should contain |
|---|---|---|
Wild-harvested macroalgae | Species, harvesting area, season, harvest year, extraction process | Species and harvesting area, marker substance with content specification, arsenic and heavy metals, iodine |
Aquacultured macroalgae | Cultivation conditions, harvest timing | Cultivation site, marker substance, contaminants |
Cultivated microalgae | Strain, culture conditions, scale | Strain, marker substance, microbiological purity |
By-products from fisheries and aquaculture | Source species, degree of processing | Animal species, origin, batch traceability |
Bogdan et al. call for standardized harvesting, cultivation under controlled conditions, and validated extraction protocols. However, cultivation does not completely solve the problem: according to Thiyagarasaiyar et al., open systems are inexpensive but easily contaminated, and closed photobioreactors have not yet achieved large-scale production. Brands should therefore clarify before formulation release whether the supplier can deliver consistent quantities from a single source and how they announce a change in harvesting area.
Which impurities must the safety assessment cover?
Algae bind minerals and metals from seawater, which is why contaminants belong in every raw material assessment. Thiyagarasaiyar et al. cite heavy metals, pesticides, and toxins as quality risks of algae-based raw materials. In Garcia-Vaquero et al., cadmium, mercury, and lead were low in all three species, but the total arsenic content was high: 49 to 64 mg/kg dry weight in Ascophyllum nodosum, and even higher in the two Laminaria species at 75 to 615 mg/kg dry weight. Iodine was about nine to ten times higher in the Laminaria species than in Ascophyllum nodosum. These values apply to the dried algae; how much of this reaches the extract and the finished product depends on the extraction process and the concentration used.
Legally, Art. 17 of Regulation (EC) No 1223/2009 applies: The non-intended presence of a small quantity of a prohibited substance, stemming for example from impurities of natural ingredients, is only permitted if it is technically unavoidable in good manufacturing practice and the product remains safe under Art. 3. Arsenic, lead, cadmium, and mercury and their compounds are listed in Annex II of the Regulation. Whether a measured trace level is acceptable is evaluated by the safety assessment in the safety report, and for this it requires data from the raw material supplier.
What this means for raw material documentation
Request a certificate of analysis per batch including arsenic, heavy metals, and microbiological purity, not just a general data sheet.
Inquire about the iodine content for brown algae extracts, especially for leave-on products applied to large areas of skin such as body care.
Treat switching to a different algae species or a different harvesting area as a formulation change that impacts the safety report and, if applicable, the stability data.
Which tests a product must complete before launch is described in the article on stability and safety testing for cosmetics.
Does the Nagoya Protocol apply to marine resources?
Generally not for the purchase of a commercially available algae extract, but often yes for research on a marine organism. Regulation (EU) No 511/2014 implements the Nagoya Protocol in the EU. According to Art. 2(1), it applies to genetic resources over which states exercise sovereign rights and where access took place after the Protocol entered into force for the Union. Pursuant to Art. 3(5), utilisation means research and development on the genetic or biochemical composition of these resources, including biotechnology.
Those who utilise have specific obligations:
Art. 4(1): exercise due diligence to ascertain that the genetic resources were accessed in accordance with applicable legislation.
Art. 4(3): seek, keep, and transfer to subsequent users information such as the internationally recognised certificate of compliance.
Art. 4(6): keep this information for twenty years after the end of the period of utilisation.
Art. 7(2): declare to the competent authorities at the final stage of product development that the obligations have been fulfilled.
These definitions establish the threshold for cosmetics: Anyone who purchases a finished extract with known properties and incorporates it into a cream or serum is generally not conducting research on the composition of the resource. Conversely, anyone who studies an algae or marine microorganism in order to obtain a compound as a new cosmetic ingredient is conducting research and development within the meaning of Art. 3(5). Since the Regulation only covers resources over which states exercise sovereign rights, resources from areas beyond national jurisdiction, such as the high seas, remain outside its scope. For these areas, the United Nations High Seas Treaty (BBNJ), which according to the European Commission also regulates the utilisation of marine genetic resources, has applied since January 17, 2026. For resources from coastal waters, national access regulations of the provider country may also apply.
For brands, this means: for a commercially available extract, the supplier's proof of origin is usually sufficient. However, anyone who has algae collected, screened, or fermented on a specific coast to develop their own active ingredient should clarify the due diligence obligations before laboratory work begins.
What formulation issues do marine active ingredients bring?
In addition to the active ingredient, marine extracts bring along accompanying substances that influence viscosity, color, odor, and preservation. The most common points from laboratory work:
Electrolytes: Mineral-rich algae extracts and sea salt components can weaken electrolyte-sensitive thickeners such as carbomers and destabilize emulsions. The choice of thickener should therefore be established together with the dosage of the extract.
Intrinsic viscosity: Polysaccharide-rich extracts themselves increase viscosity. A change in dosage therefore alters texture, spray pattern, and filling behavior, for example in pump dispensers and airless systems.
Color and odor: Brown and green algae extracts impart color to formulations and smell of the sea. In light-colored creams and serums, and especially in complexion products like skin tints, this must be taken into account during shade matching; a new extract batch can shift the color.
Preservation: Water-based, nutrient-rich extracts increase microbiological load. The preservation efficacy test according to ISO 11930 should be conducted on the final formulation with the extract actually used, not on a base without the active ingredient.
Temperature and oxidation sensitivity: Even during extraction, high power, temperature, and pressure degrade phenolic compounds (Thiyagarasaiyar et al.). For formulations with phlorotannins or carotenoids, a cold addition phase, light-protected and ideally airtight packaging, and stability testing under temperature and light exposure are recommended.
Minimum scope of the test protocol
A formulation with algae extract should be tested in the final packaging for viscosity, pH value, color, odor, and phase separation, as well as for packaging compatibility and with the preservation efficacy test. If the supplier can provide two extract batches, it is advisable to sample both: this reveals early on whether variability in the raw material becomes visible in texture or color.
Which advertising claims do marine active ingredients carry?
The claim "with marine algae" requires that the ingredient is actually present; an effect of the finished product does not automatically follow. According to the criterion of truthfulness in Regulation (EU) No 655/2013, the property of an ingredient must not be presented as if the finished product has it if this is not the case. The criterion of evidential support requires proof for this transfer, such as that the ingredient is present in the product in an effective concentration. In vitro data from the raw material supplier therefore do not support a product claim if the concentration used in the product is significantly lower than the concentration tested.
Special Case: UV Protection
MAAs from algae absorb UV radiation, but an extract containing MAAs may neither be used as a UV filter nor advertised as sun protection. A substance that is exclusively or predominantly intended to protect the skin against UV radiation by absorbing, reflecting or scattering it is a UV filter pursuant to Art. 2(1)(n) of Regulation (EC) No 1223/2009, and pursuant to Art. 14(1)(e), only the filters listed in Annex VI are permitted. A review on MAAs as sunscreen actives (Rosic et al., 2023) also cites low extraction yields as the reason for the low industrial use; in commercial raw materials containing MAAs from Porphyra umbilicalis, the MAA content is low, and they protect in the UVA rather than the UVB range. In a study cited there on two red algae species, the sun protection factor increased with the MAA content, reaching 7.5 at the highest yield. Such an extract can serve as a conditioning active ingredient in a sunscreen product with approved filters, but not as a filter itself.
The same principle of substantiation applies to "sustainably harvested": The claim requires supplier documentation on the harvesting area and harvesting or cultivation methods. You can find more on the limits of cosmetic claims in the article on cosmetic advertising claims in the EU.
The reliable approach starts with the raw material's function and the intended claim, not with its origin. In practice, this sequence has proven effective:
Define function and claim: Structuring agent, conditioning active ingredient, or origin argument, and which claim needs to be substantiated on the finished product.
Qualify the raw material: Request specification with marker substance, certificate of analysis covering arsenic, heavy metals, and microbiology, information on origin, and Nagoya status from the supplier.
Laboratory samples with realistic use concentrations: Test texture, color, and odor at the dosage that must later substantiate the claim.
Stability and preservation in final packaging: Stability testing, packaging compatibility, and preservation efficacy testing according to ISO 11930 on the final formulation.
Safety report and Product Information File: Raw material data and trace evaluations are incorporated into the safety report, and claim substantiations into the Product Information File pursuant to Art. 11 of Regulation (EC) No 1223/2009 before the responsible person registers the product in the CPNP.
Labtree is a B2B cosmetic developer and cosmetic manufacturer with its own laboratory and production capacities in Germany, covering formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production. Samples of pre-qualified formulations typically ship from the sample warehouse within 24 hours; standard samples are free of charge. If a tested Labtree formulation is adapted and supplemented with a marine active ingredient (White Label), the product is usually ready for delivery within 2 to 3 months with standard packaging, provided that the active ingredient does not alter the stability of the base. A new development as a Private Label typically takes 3 to 6 months because stability testing and regulatory timelines dictate the schedule. The minimum order quantity is generally 1,500 units per product, depending on the product type, fill size, and packaging. The process from conception to production is described on the page Have cosmetics developed.
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FAQ
Are marine ingredients more effective than land-based ingredients?
Not fundamentally. Marine raw materials supply different classes of substances, such as sulfated polysaccharides or phlorotannins, but the effect in the product depends on content, application concentration, formulation, and stability. An efficacy claim always requires proof for the finished product.
Is farmed seaweed more consistent than wild-harvested seaweed?
As a rule, the composition can be better controlled with cultivated cultivation because location, conditions, and harvest time are fixed; Bogdan et al. mention it as a way to achieve more consistent raw materials. It does not replace batch testing, because extraction methods and process conditions also alter the content. In the case of microalgae, an additional factor is that open cultivation systems are easily contaminated.
What does Blue Beauty mean in cosmetics?
Blue Beauty is a marketing term for products that use marine-derived ingredients or emphasize ocean conservation; there is no legal definition. Therefore, advertising claims are subject to the general criteria of Regulation (EU) No 655/2013, particularly regarding truthfulness and evidential support. Claims regarding sustainable harvesting require documentation from suppliers.
Can a product containing algae extract be advertised as natural cosmetics?
The Cosmetics Regulation does not define natural cosmetics. Brands therefore rely on calculating natural content according to ISO 16128 or on private certification standards with differing criteria. A single algae extract does not make a product natural cosmetics; what matters is the overall formulation.
Does a tested base formulation require a new stability test after adding an algae extract?
Yes, usually. Electrolytes, inherent viscosity, color, and microbiological load of the extract alter the formulation, which is why stability testing and preservative challenge testing should be performed on the final version. Details are described in the magazine article “Stability and Safety Testing for Cosmetics”.
What does the High Seas Treaty (BBNJ) change for marine active ingredients?
The agreement entered into force on January 17, 2026, and regulates, among other things, the use of marine genetic resources from areas beyond national jurisdiction, which are not covered by the Nagoya Regulation (EU) No 511/2014. It binds the contracting parties, who implement its rules into national law; what obligations this entails for companies depends on this implementation. Anyone wishing to use samples from the high seas for their own active ingredient should check the status before starting the project; for commercially available extracts, little will change initially.
How long does it take to develop a serum with a marine active ingredient?
The framework is set by the service model: Adapting a tested formulation (White Label) is faster than a new development (Private Label), the timeline of which is determined by stability testing. With the marine active ingredient, additional time factors come into play, especially qualifying a supplier with a batch specification and certificate of analysis, as well as sampling at the actual application concentration. If the Nagoya status is pending, it should be clarified before starting laboratory work.
