The topic is short and compact
Each additional customized dimension typically affects the safety report: composition, stability, preservation, packaging, or toxicological profiles.
Anyone who transfers properties of an active ingredient to the product requires sufficient evidence under Regulation (EU) No. 655/2013, such as an effective concentration in the product.
The sensory feel of a skin care emulsion is primarily determined by the emulsifier system; iterations swapping emollients within the same system will achieve very little.
Greater development depth is worthwhile for protectable innovations, novel ingredients, sensitive target audiences, or study-based positioning.
Each packaging type and, where applicable, each fragrance variant requires its own stability test; accelerated tests typically run for one to three months.
So läuft die Entwicklung bei Labtree
1
Konzeptionierung
2
Bemusterung – Standardmuster in 24 h
3
Individualisierung
4
Prototyping
5
Produktion
White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
What does overengineering mean in cosmetics development?
Overengineering means: A project customizes more dimensions than its positioning requires. Typical is a formulation with many active ingredients, a custom delivery system, a special shape for packaging, and additional certificates, even though the brand ultimately aims to sell itself based on a single efficacy claim and texture.
The effort does not lie in the idea, but in the documentation. The cosmetic product safety report according to Annex I Part A of Regulation (EC) No. 1223/2009 requires, among other things, the qualitative and quantitative composition with the function of each substance (No. 1), the stability under reasonably foreseeable storage conditions (No. 2), the results of the preservation challenge test (No. 3), the relevant characteristics of packaging material (No. 4), and the toxicological profiles of all contained substances (No. 8) for every product. Every additional raw material, every new packaging variant, and every change in formulation updates at least one of these points.
Overengineering is therefore not a quality feature, but a planning problem: More variables mean more iterations during sampling, longer testing periods, and more points where a project can fail shortly before production.
Where does overengineering occur in the formulation?
Active ingredient oversaturation
Ten active ingredients in a serum sound like performance, but from a formulation perspective, they are ten variables: different pH windows, interactions with the emulsifier, influence on color and odor, and an additional burden on the preservation system. On top of that comes the advertising claim. According to the common criteria of Regulation (EU) No 655/2013, a claimed ingredient must be deliberately present (Annex No 2.1), and anyone attributing properties of an ingredient to the final product requires adequate substantiation, such as an effective concentration in the product (No 3.6). An active ingredient in trace amounts that merely decorates the INCI list is therefore not a differentiator, but a risk for substantiation.
Proprietary delivery systems without justification
A newly developed emulsion system has no stability history. Where a proven system already achieves the desired texture, in-house development primarily prolongs the testing phase.
Fragrance as a permanent work in progress
Perfume oil changes may seem minor, but they are not. The safety report lists fragrance compositions by code number and supplier (Annex I Part A No 1), and the Cosmetics Europe stability guidelines point out that fragrances are more likely to interact with the product than shade variations. The guidelines therefore consider it advisable, under certain circumstances, to test each fragrance variant separately.
Why does sensory micro-optimization yield so little?
Texture is predominantly determined at the system level, not in the details. In a study by Baki et al. (Journal of Cosmetic Science, 2018), 50 untrained consumers evaluated six emulsions across three system types: sterically stabilized O/W, liquid crystalline stabilized O/W, and W/O emulsions. Within a single type, the samples differed only in the emollient and exhibited similar sensory properties. The authors conclude that the emulsifier, rather than the emollient, dominates the aesthetics of a skincare emulsion.
For sampling, this means: The fundamental decision regarding the emulsion system and the target sensory profile belongs at the beginning. Five more rounds swapping oils within the same system often barely change the result for the target audience, but each costs a new sampling round and potentially a new stability run.
A measurable target sensory profile is helpful. Anyone who defines viscosity with measurement temperature and spindle, spreading behavior, and appearance against a reference sample as a specification after sample approval replaces recurring subjective discussions with test criteria that also apply to later batches. How such approval rounds can be streamlined is described in the article on coordination loops in cosmetic development.
Which packaging and variant decisions take up the most time?
Packaging materials are part of stability testing, not just design. The Cosmetics Europe stability testing guidelines recommend testing with packaging materials made of the exact same material as used on the market, examining each packaging type separately, and including the smallest container size when multiple sizes exist. Tested factors include interactions such as adsorption, migration, and corrosion, as well as the barrier against oxygen and water vapor. Accelerated tests often run at 37 °C, 40 °C, or 45 °C over one, two, or three months, depending on the product type.
What this means for typical custom requests
Custom shape for jar or bottle: Tooling, sampling of the packaging material, change parts on the filling line, and a separate skin compatibility test. A standard container with brand decoration is already tested and available.
Multiple container sizes at launch: According to the guidelines, the smallest container is usually sufficient for stability, but each size entails separate packaging material orders, change parts at filling, and distinct labels.
Extensive shade ranges for complexion products: For concealer or skin tint, representative extreme shades are tested according to the guidelines; nonetheless, each shade requires shade matching, color measurement against a standard, and batch-to-batch consistency in production.
Applicators and special pumps: They alter dosing and wiping behavior and must match the viscosity of the bulk product.
The article Stability and Safety Testing for Cosmetics summarizes which tests must be completed before launch.
What actually differentiates a cosmetic product?
The formulation can differentiate two things: a substantiated efficacy claim and a recognizable sensory profile. Brand presence, price point, and delivery capability are also decisive for purchasing decisions, but are not resolved in the formulation.
An efficacy claim only differentiates if it is substantiated and does not merely describe what comparable products also achieve. Regulation (EU) No 655/2013, in Annex No. 4.2, prohibits attributing specific characteristics to a product if similar products have the same characteristics, and requires in No. 4.1 that claims regarding efficacy do not go beyond the available evidence. At the same time, the product information file under Art. 11(2)(d) must contain the proof of the effect claimed for the cosmetic product, where justified by the nature or effect of the product.
Dimension | Customize if | Standardize if |
|---|---|---|
Active ingredient concept | the central claim depends on it and needs to be substantiated | the active ingredient only supplements the INCI list |
Texture and sensory profile | the profile is part of the positioning | the target group perceives no difference to the proven system |
Carrier system | no proven system carries the target texture or the active ingredient | stability data is available for a comparable system |
Packaging | application or active ingredient protection technically require it | decoration and label sufficiently convey the brand |
Certificates and studies | retailers or the target market specifically demand them | no buyer asks for them |
How efficacy claims are properly substantiated is explored in depth in the article on cosmetic claims in the EU.
What does a focused product definition look like in practice?
Example: Anti-aging cream
A brand positions an anti-aging cream via a peptide complex with proven efficacy. Two dimensions are individualized: the peptide complex in a concentration for which efficacy studies are planned, and a rich, fast-absorbing texture as a sensory profile. The emulsion system, a tested glass or airless container with brand decoration, and the preservation system—for which challenge test results in a comparable matrix are already available—are standardized. This does not eliminate the challenge test for the finished product, but makes its outcome much more predictable.
Example: Skin tint
With a skin tint, differentiation lies in the shade range and finish. The base, packaging material, and applicator are selected from tested solutions so that laboratory time can be dedicated to shade development, pigment dispersion, and batch consistency across all shades.
The Cosmetics Europe guideline explicitly mentions existing data on similar products with similar packaging as a starting point for a stability program. This is precisely where a pre-qualified formulation base comes in. Labtree works as a B2B cosmetics developer and cosmetics manufacturer with its own laboratory and production facility in Germany: formulation development, sampling, feasibility testing, and cosmetics production fall under the same responsibility. In the White Label model, tested Labtree formulations are customized for the brand and are typically ready for delivery in standard packaging within 2 to 3 months; the formulation remains the property of Labtree. Private label, i.e., new development according to the brand's requirements, usually takes 3 to 6 months to reach market readiness. Samples of pre-qualified formulations typically ship from the sample warehouse within 24 hours; the minimum order quantity is generally 1,500 units per product, depending on product type, fill size, and packaging.
Greater development depth is not a mistake if it serves a specific purpose:
Protectable innovation: Proprietary technology that can be patented or protected as know-how justifies longer development times.
Sensitive target groups and application areas: For products used around the eyes, on mucous membranes, or for children under three years of age, Annex I Part A No. 3 of Regulation (EC) No. 1223/2009 requires special attention regarding microbiological quality. Additional evaluation effort is part of the safety assessment here and is not optional.
New ingredients: A raw material without robust data requires a toxicological profile for all relevant endpoints. The data and test methods expected for this are described in the SCCS Notes of Guidance (12th Revision). This can be planned, but it is not a project for a quick initial launch.
Scientific positioning: A brand that relies on its own studies requires studies that, according to Annex No. 3.3 of Regulation (EU) No. 655/2013, are relevant to the product and benefit and are based on valid, reliable, and reproducible methods.
The order is crucial: first determine which dimension justifies the effort, then develop. Why projects often stall without this determination is shown in the article Why Cosmetic Projects Fail.
More useful links
FAQ
How do I know if my cosmetic project is overengineered?
Typical signs are sampling rounds whose differences are only noticed by the internal team, a formulation with active ingredients without corresponding advertising claims, and packaging decisions that dictate the timeline. A helpful approach is to create a list of all customized dimensions, asking which of them the customer actually perceives on the shelf.
How many active ingredients make sense in a formulation?
There is no set number. Every active ingredient should have a clear function and, if claimed, be used at a concentration that supports the advertising claim. Active ingredients in trace amounts increase formulation and documentation effort without providing a verifiable benefit.
Does stability testing have to be restarted after every formulation change?
According to the Cosmetics Europe guidelines, stability testing is intended to ensure that a modified product also meets the intended quality requirements. A change in formulation therefore generally requires new stability data; the extent required is assessed by the laboratory and the safety assessor based on the nature of the change. It is advisable to bundle changes rather than introducing them individually one after another.
Does a brand lose differentiation when it uses a white-label formulation?
Not necessarily. With white label, a tested formulation from the manufacturer is adapted, such as in fragrance, color, or active ingredient focus, while the formulation remains with the manufacturer. Those who need exclusivity for the formulation itself choose private label; the trade-offs are described in the magazine article on the advantages and limits of white label cosmetics.
Is custom packaging worth it for the very first launch?
Usually only if the application or active ingredient protection technically requires it. Anyone switching later will need stability data in the new packaging material, as testing is conducted in the material in which the product is sold. It is therefore advisable to plan the switch in conjunction with an already scheduled formulation revision or product range expansion.
Do I need a separate study for every advertising claim?
No. According to Regulation (EU) No 655/2013, claims must be supported by adequate and verifiable evidence whose evidentiary value is appropriate to the nature of the claim. The type of evidence is open, including expert opinions, and the weight of all available studies, data, and information is evaluated; clearly exaggerated or abstract claims do not require substantiation. For further details, read the magazine article on cosmetic claims in the EU.
