The topic is short and compact
Source storytelling only holds weight if the origin, extraction method, and active concentration of the raw material are documented and genuinely present in the formulation.
Marine, microbial, and plant-based sources differ in batch-to-batch variation and availability; the raw material specification must reflect this.
According to the common criteria for advertising claims, the properties of an ingredient may not be transferred to the finished product without evidence.
For marine and plant-derived natural substances, ABS documentation in accordance with Regulation (EU) No 511/2014 is one of the documents that should be available before the launch.
As of September 27, 2026, general environmental claims and statements about an entire product that relate to only one raw material are prohibited when addressed to consumers.
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Why is differentiation shifting from the active ingredient to the origin?
A new active ingredient sets a product apart as long as few brands use it. As soon as it appears in many skin tints, serums, or creams, its mere presence is no longer a selling point. Differentiation does not disappear then; it shifts to a different level: How is the active ingredient sourced, from which raw material, and by which process?
This is easy to observe with regenerative active ingredients like PDRN. The more products with the same INCI name enter the market, the more the source takes center stage, such as the question of biotechnological versus animal sourcing. The magazine article on PDRN in cosmetics describes the development of this category.
For product management and purchasing, this has a practical consequence: origin becomes a specification. Those who advertise the source must establish it in the raw material, check it for every batch, and be able to maintain it when changing suppliers. The article on active ingredient strategy in cosmetics shows how an active ingredient can be evaluated independently of its media hype.
What origin narratives exist and what do they mean technically?
Most origin stories fall into three groups. None is fundamentally superior to the others; however, they differ significantly in raw material availability, batch-to-batch variation, and documentation effort.
Origin | Typical narrative | Technical consequence |
|---|---|---|
Marine (algae, microalgae, fisheries by-products) | Ocean, biodiversity, natural substance with a high research component | Limited quantities, fluctuating composition depending on location and harvest time, traceability back to extraction |
Microbial or biotechnological (fermentation) | Precision, reproducibility, controlled manufacturing | Outcome depends on strain and process conditions; aqueous filtrates place demands on preservation |
Plant-based (extracts, oils, butters) | Botanical origin, regional cultivation | Seasonal variation, color and odor vary between harvests, proof of cultivation and origin |
For marine raw materials, a review in Marine Drugs describes that many compounds occur only in small quantities and their composition depends on non-constant environmental conditions. For the formulation, this means: the specification of the extract requires narrow limits for dry matter, salt content, and marker substance. A higher electrolyte content, for example, can significantly lower the viscosity of a gel thickened with carbomer.
Fisheries by-products, such as collagen from fish skin, represent their own narrative. According to an evaluation in Marine Drugs, around a quarter of annual marine production is discarded as a by-product; however, so far only a few cosmetic raw materials derived from it reach the market, partly due to raw material supply and extraction costs. Anyone promoting upcycling should therefore verify supply reliability over several production runs.
For fermented raw materials, a review in Molecules emphasizes that the process depends primarily on the choice of the microorganism strain. A ferment is therefore only as reproducible as the strain, nutrient medium, and process control at the raw material manufacturer. You can find more in-depth fundamentals on marine sources in the article on marine active ingredients in cosmetics.
What does cosmetics law require from a claim of origin?
An origin claim is an advertising claim. According to Article 20(1) of Regulation (EC) No 1223/2009, text, names, trademarks, and figurative or other signs shall not be used to imply that these products have characteristics or functions which they do not have. In addition, the claim must meet the common criteria set out in the Annex to Regulation (EU) No 655/2013: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. Pursuant to Article 1 of this Regulation, this also applies to pictures, product names, and brands that imply an origin.
The Technical Document of the EU Working Group on Cosmetic Claims fleshes out these criteria with examples. Three points are crucial for origin claims:
Intentionally present: If an ingredient is advertised, it must be deliberately in the formulation. The document gives honey as an example: a product advertising honey must contain honey, not just honey aroma. By analogy, this means: a marine scent does not substantiate a claim about a marine extract.
No extrapolation without substantiation: Properties of an ingredient must not imply that the finished product also possesses them. Anyone extrapolating them requires evidence, such as proof of an effective concentration in the product.
Substantiation remains up to date: The responsible person must ensure that the evidence remains valid even after a formulation change. A change of the extract supplier should therefore be treated like such a change.
The substantiation belongs in the product information file. The Technical Document refers here to Article 11(2)(d) of the Cosmetics Regulation, the proof of the effect claimed for the cosmetic product. According to its own statements, the document is not legally binding; it is intended as a collection of best practices for case-by-case application, on which the competent authorities and courts of the Member States decide. How the criteria are applied to effect and "free-from" claims is described in the article on cosmetic advertising claims in the EU.
What has applied to environmental and sustainability claims since September 27, 2026?
Many origin stories are also environmental claims: sustainably harvested, derived from by-products, resource-efficiently fermented. For these claims made to consumers, the Directive (EU) 2024/825 on empowering consumers for the green transition applies. Member States had to transpose it by March 27, 2026, and have been applying the provisions since September 27, 2026.
For cosmetics brands, four amendments to Directive 2005/29/EC on unfair commercial practices are relevant, three of which are in the list of practices considered unfair in all circumstances in Annex I:
Generic environmental claims: Terms such as “environmentally friendly,” “green,” “nature’s friend,” or “ecological” are inadmissible without proof of recognized excellent environmental performance if the specification is not clearly and prominently provided on the same medium (Annex I No. 4a).
Aspect vs. entire product: An environmental claim concerning the entire product is prohibited if it relates only to a single aspect (Annex I No. 4b). A sustainably sourced algae extract does not make a cream sustainable as a whole.
Sustainability labels: A sustainability label must be based on a certification scheme or established by public authorities (Annex I No. 2a). Self-designed logos that signal sustainability in combination with an origin claim fall under this without such a scheme.
Forward-looking claims: Claims regarding future environmental performance are considered misleading under the new Art. 6 para. 2 point (d) without a publicly available implementation plan containing measurable, time-bound targets that is regularly monitored by independent third-party experts.
In practical terms, this means: A specific, substantiated origin claim such as “brown algae extract harvested in Brittany” is easier to defend than a general sustainability promise. Existing packaging materials with blanket environmental terms should be reviewed before the next production run, as label changes are tied to print lead times and packaging inventory.
When does the Nagoya Protocol apply to natural substances?
The starting material of marine, microbial, and plant active ingredients, i.e. algae, microorganisms, or plants, is frequently a genetic resource within the meaning of the Nagoya Protocol. In the EU, Regulation (EU) No 511/2014 implements the Protocol. It obliges users, meaning companies that conduct research and development on the genetic or biochemical composition of such resources (Art. 3 Nos. 4 and 5), to exercise due diligence regarding access and benefit-sharing. Pursuant to Art. 2(1), it applies to resources accessed after the Protocol entered into force for the Union.
Pursuant to Art. 4(3) of the Regulation, users must seek, keep, and transfer to subsequent users the internationally recognized certificate of compliance or, where not available, information such as the date and place of access and the source of the resource. According to Art. 4(6), the documents must be kept for twenty years following the end of the period of utilization.
Whether a brand itself is a user depends on the project. If it purchases a fully developed extract and uses it in a formulation, research and development generally lies with the raw material manufacturer. If, on the other hand, it commissions specific research on a new algae, a new strain, or a new plant source, it may itself fall within the scope of application. In both cases, it is advisable to request the ABS documentation for the raw material: an origin story whose access to the resource has not been clarified is a reputational risk.
Which documents and tests are required for a reliable statement of origin?
An origin claim is based on three levels: raw material, formulation, and finished product. Documentation should be available for each level prior to launch.
Raw material level
Specification with botanical or biological origin, plant part or organism used, method of obtaining (wild harvesting, aquaculture, cultivation, fermentation), and country of origin
Certificate of analysis per batch, with limit values for marker substance, dry matter, and microbiological quality
ABS documentation and, if advertised with a seal, the certificate from the certification system
Contractual obligation of the supplier to notify changes of source or process in advance
Formulation level
Use level that actually delivers the advertised property, rather than a trace amount for the INCI list
Comparison of multiple raw material batches in laboratory samples: color, odor, viscosity, and pH; plant extracts frequently alter the color shade and odor of an emulsion with changing harvests
Stability testing with the final raw material quality and preservative challenge test according to ISO 11930, especially for aqueous ferment filtrates and extracts
Product level
Evidence for every claim in the product information file, coordinated with the safety assessment
Review of product name, imagery, and packaging text for claims that exceed the evidence
In the case of claimed natural content, a calculation according to the voluntary guideline ISO 16128 instead of arbitrary percentage figures
Whether an origin story holds up is decided during formulation development, not on the label. The source must be determined before the formulation, so that the preservation system, thickener, and emulsifier can be matched to the actual raw material. An extract that is only replaced after approval requires new samples, a new stability test, and a review of the claims.
Labtree is a B2B cosmetics developer and cosmetics manufacturer with its own laboratory and production capacities in Germany. Formulation development, sampling, feasibility testing, and cosmetics production fall under a single responsibility, meaning the raw material source can already be defined and documented during formulation development. Samples of pre-qualified formulations typically ship from the sample warehouse within 24 hours. A white-label formulation with standard packaging is generally deliverable in 2 to 3 months, while a new private-label development usually takes 3 to 6 months; the minimum order quantity is typically 1,500 units per product, depending on the product type, fill size, and packaging. The project process is described on the page Having cosmetics developed.
No manufacturer can guarantee approval or claim conformity. What development can provide is a formulation whose raw material source, concentration, and batch behavior are documented, allowing the responsible person to base their origin claim on solid documentation.
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FAQ
Is “marine” or “plant-based” a protected term in cosmetics?
The Cosmetics Regulation does not specifically define such terms of origin. The common criteria of Regulation (EU) No 655/2013 are decisive: the advertised ingredient must be intentionally included, and the claim must not imply a characteristic that the product does not have.
Can a brand advertise using the country of origin of an active ingredient?
Yes, as long as the information is accurate and supported by specifications and proof of supplier. However, the statement must not give the impression that the entire product originates from this country or that it has a special effect as a result.
Can "sustainable" still be on packaging since September 2026?
As a general environmental claim, only permissible with proof of recognized excellent environmental performance or if the specific explanation is clearly and prominently displayed on the same medium. A specific statement regarding an individual raw material is possible, but must not be applied to the entire product.
Does an algae extract require Nagoya documentation?
Algae are generally considered genetic resources. The due diligence obligations under Regulation (EU) No. 511/2014 primarily apply to the raw material manufacturer that researches and develops the extract; however, the brand should still request and retain the documentation, especially if it promotes the origin of the ingredients.
What happens to the origin claim if the raw material supplier changes?
A change of supplier should be treated like a formulation change. Specification, stability, preservation, and the supporting evidence for claims must be re-evaluated before the next batch is released. The Labtree magazine article on cosmetics post-production describes how such changes can be planned in advance.
Who owns a formulation that is developed around a specific raw material source?
That depends on the service model. With white label, the standard formulation remains with the manufacturer and is adapted for the brand; with private label, the formulation is newly developed, and formulation rights or exclusivity can be contractually transferred to the brand.
