The topic is short and compact
A brief with measurable targets and an actual baseline formulation shortens the search phase more effectively than any extra round of coordination.
Formulation changes after the start of stability testing cost the test time that has already elapsed, which is why sensory decisions must be made before starting the test.
Stability, preservation, and migration depend on the specific packaging material, which is therefore determined alongside the formulation and tested in the original container.
Post-launch defects are the most expensive form of failure, as the person responsible must take corrective action—up to and including a product recall—in the event of non-compliance.
Laboratory results do not automatically apply at production scale; a batch produced on production-scale equipment and a filling test close this gap.
So läuft die Entwicklung bei Labtree
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Konzeptionierung
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Bemusterung – Standardmuster in 24 h
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Individualisierung
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Prototyping
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Produktion
White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
What does failure mean in a cosmetics project?
Failure in cosmetics development is rarely a clean break. In practice, it manifests in four forms that often overlap:
Delayed launch: The date is pushed back by months, retail listing discussions, packaging orders, and marketing planning have to be rescheduled.
Reduced scope: A planned color range of eight shades is cut down to four because not all shades are finalized and stable in time.
Cancellation and restart: The project is restarted with a different manufacturer; formulation, testing, and documentation partially begin from scratch.
Launch without substance: The product enters the market, but fails to maintain stability, microbiological quality, or performance promises.
The last form is the most expensive because it only occurs after placing on the market. If the product does not comply with the regulation, the responsible person must immediately take corrective measures pursuant to Art. 5(2) of Regulation (EC) No 1223/2009 and, if necessary, withdraw or recall the product from the market. The role played by microbiological defects is demonstrated by an evaluation of the European rapid alert system RAPEX: of the 243 microbiologically contaminated consumer products reported between 2005 and 2017, 111 were cosmetics; in around 89 percent of these cases, the permissible total viable count was exceeded.
Why does a brief without a formulation baseline lead to endless searching?
A project that starts with an abstract wish such as "rich day cream with anti-aging effect" spends its first weeks searching rather than developing. As long as it remains unclear which emulsion base, which lipid system, and which active ingredient proportion are technically viable, the briefing is refined anew in every coordination round.
A reliable briefing therefore establishes measurable target values and framework conditions before the first sample is created:
Product type and format: such as skin tint in a pump bottle, concealer with applicator, or cream in a jar
Sensory profile and performance: texture, coverage, finish, and longevity on the skin, ideally with a benchmark product as a reference
Technical key parameters: pH range, target viscosity, pouring temperature for hot-pour formats
Marketing claims: which effects should be claimed, as substantiation for these subsequently belongs in the product information file in accordance with Art. 11(2)(d) of Regulation (EC) No 1223/2009
Commercial framework: target price per unit, planned volume per product, and required packaging material
A project materializes most quickly when it is based on an existing, already tested formulation and defines only the deviations. The team is then no longer discussing concept papers, but differences from an actual product: more glide, a more matte finish, a different fragrance. Whether the project continues as a white label with an adapted manufacturer formulation or as a new development under private label is a question of exclusivity and timeframe, not of the starting point.
Why do late samples become more expensive than early ones?
If the first physical sample is not available until weeks after the project launch, decisions until then are made on paper: packaging materials are requested, artwork is started, and the launch date is committed to internally. As soon as the sample is on the table, questions arise that were thought to have been resolved. The cream absorbs more slowly than expected, the concealer darkens on the skin, the stick breaks when twisted up.
The real loss of time occurs afterward. According to Art. 10(1) of Regulation (EC) No 1223/2009, the safety assessment relates to the final composition, and stability data only apply to the tested formulation. Therefore, a change after the start of testing generally calls the ongoing test into question. According to the Cosmetics Europe stability guidelines, accelerated storage tests often run at 37, 40, or 45 °C over one, two, three, or more months, depending on the product type. A change in formulation in the second test month therefore costs not only laboratory work, but also the testing time that has already elapsed.
Early samples move sensory and technical decisions ahead of the start of testing. The sequence is then: evaluate samples, freeze formulation, start testing. How early physical evidence also makes budget decisions more reliable is described in the article Samples before budget release.
Why do sequential processes fail when it comes to packaging materials and safety assessment?
In the classic process, the final formulation is followed by packaging selection, then safety assessment, and finally production planning. Each transition is a point where a late-discovered problem can set the process back. Most frequently, this affects the packaging material.
The safety report pursuant to Annex I of Regulation (EC) No 1223/2009 requires information on the stability of the product under reasonably foreseeable storage conditions, the results of the preservation challenge test, and the relevant characteristics of the packaging material, in particular purity and stability. All three depend on the specific packaging material:
Stability: Cosmetics Europe guidelines recommend testing in packaging made of the exact same material in which the product is sold, for multiple sizes in the smallest container, and where applicable in different orientations. The same packaging material is therefore recommended for both laboratory and production; a glass jar from the laboratory serves as a control, but does not replace the subsequent PP jar.
Migration: In seven plastic cosmetic packaging materials made of PP, PE, and SAN, Murat et al. (2020) found 35 volatile and semi-volatile compounds, including phthalates, styrene, and non-intentionally added substances. Whether they migrate into the formulation must be tested separately.
Preservation: According to the review by Halla et al. (2018), jars and bottles are more susceptible to microbial contamination than airless dispensers, tubes, or narrow-opening pumps, and packaging materials can alter the effectiveness of the preservative system through migration or adsorption. The challenge test itself runs for 28 days. If the format changes late, the preservative system should be re-evaluated.
The consequence is a parallel process: the packaging material is determined together with the formulation, stability and challenge tests start in the original container, and the product information file pursuant to Art. 11 grows with the project. Notification in the CPNP pursuant to Art. 13 only takes place before placing on the market, but the relevant documentation is then already available. Which tests must be completed before launch is summarized in the article on stability and safety testing for cosmetics.
What is missing when the manufacturer has no in-house development depth?
If a manufacturer merely selects formulations from a catalog or passes adjustments on to an external laboratory, every corrective step is out of their control. This becomes apparent in three areas:
Formulation adjustments take longer because the inquiry, laboratory work, and feedback loop run across two organizations.
Stability abnormalities such as phase separation, viscosity drops, or color drifts are detected late because small test batches are not produced in-house.
Filling requirements are not incorporated into the formulation because formulation development and manufacturing are organizationally separated.
When choosing a partner, it is therefore worth asking who develops the formulation, who modifies it when issues arise, and where sample quantities are produced. Labtree is a B2B cosmetics developer and cosmetics manufacturer from Hamburg with its own laboratory and production capacities in Germany: Formulations are developed, adjusted, and sampled in the laboratory; manufacturability is already tested during development rather than only upon scaling up to production; and approved formulations proceed directly to manufacturing. Samples of pre-qualified formulations typically leave the sample warehouse within 24 hours.
Why does the transition from the lab to production fail?
A formulation that is stable in a laboratory batch does not automatically behave the same in a production vessel. Shear forces during homogenization, heating and cooling rates, stirring times, and the order of phase addition change with the batch size. This affects the droplet size and viscosity of an emulsion just as much as the pigment dispersion of a foundation or the solidification behavior of a hot-poured stick.
The Cosmetics Europe guidelines account for this with a dedicated stage: initial stability conclusions are based on laboratory batches, more precise ones on batches produced with equipment that corresponds to subsequent series production. Equipment type, process, and batch size belong in the test protocol. For color ranges, the guidelines recommend also testing the shades and fragrance variants with the presumably most critical properties; fragrance variants interact with the product more frequently than color shades do.
In addition, there are filling limitations that remain invisible in the laboratory: a texture that pours cleanly into the jar by hand may string on the filling machine, a pump will not dispense reliably if the viscosity is too high, and a hot-pour mass may sediment in the holding tank before filling. Production itself must follow Good Manufacturing Practice in accordance with Art. 8 of Regulation (EC) No 1223/2009; according to the Federal Office of Consumer Protection and Food Safety, compliance is presumed if manufacturing complies with the harmonized standard DIN EN ISO 22716. The path via the pilot batch to series production is described in the article Scaling cosmetic production.
The five causes manifest themselves through signals that can be evaluated within the very first weeks of the project:
Signal in the project | Probable cause | Verification question |
|---|---|---|
The briefing is still being rewritten after several rounds, a reference product is missing | Development without a formulation basis | Is there an initial formulation or a benchmark with measurable target values? |
The first sample is only planned after packaging material and artwork decisions | Late samples | Are sensory decisions made before the start of testing? |
Stability testing is conducted in laboratory glassware; the sales packaging is still open | Sequential process | Has the original container been procured and included in the test plan? |
Formulation changes are passed on to an external laboratory | Lack of development depth | Who modifies the formulation, and where are sample quantities produced? |
The schedule does not include a production-scale batch or a filling test | Late transition to production | Have the batch size, facility, and filling machine been tested prior to series production? |
If two or more signals apply, it is worthwhile to review the schedule before incurring further costs for packaging materials and artwork. The article Avoiding Launch Delays describes how deadlines can be further secured.
A clean process reduces structural risks, but does not eliminate them all. Three remain:
Regulatory changes: The Commission may amend Annexes II to VI under Article 31 of Regulation (EC) No 1223/2009 after consulting the SCCS, and substances classified as CMR are generally prohibited under Article 15. If an ingredient becomes subject to a ban or a new maximum concentration during development, the formulation must be adjusted.
Market changes: A technically finished product can lose its commercial rationale if retail requirements, price points, or the competitive environment shift.
Strategic brand pivots: If the positioning or target group changes fundamentally, a restart is part of reality and not a process failure.
Therefore, realistically, the goal is not to rule out failure, but to address the five structural causes early on so that only the risks lying outside of formulation, testing, and production remain.
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FAQ
How long does it realistically take to develop a cosmetic product?
This depends primarily on whether an existing formulation is being adapted or newly developed. At Labtree, white label products with standard packaging are generally ready for delivery in two to three months, while private label new developments typically take three to six months. Key time factors include the availability of raw materials and packaging, as well as the completion of stability tests. For a closer look at the individual drivers, see our magazine article on realistic timelines in cosmetics development.
Does the stability testing have to be carried out in the commercial packaging?
Cosmetics Europe guidelines recommend testing in packaging made from the exact same material as used for sale, and including the smallest container size if there are multiple sizes. This is due to interactions such as migration, the adsorption of ingredients, or an inadequate barrier against oxygen and water vapor. Using a glass container as a control is useful, but does not replace the original packaging.
From when should the packaging material be finalized?
At the latest before the stability test and preservative challenge test start, as both should be carried out in the original packaging. Because packaging materials have their own lead times and minimum order quantities, it is advisable to procure packaging samples already during the sampling phase. A later switch, such as from a jar to an airless dispenser, alters the requirements for the preservation system.
Who is responsible if a product is non-compliant after launch?
Under Article 5(2) of Regulation (EC) No 1223/2009, the responsible person must immediately take corrective action or, if necessary, withdraw or recall the product from the market. In the case of contract manufacturing, this is usually the brand, as it places the product on the market under its own name. It may transfer this role to the contract manufacturer by written mandate.
Who owns the formulation if a project is cancelled?
This is governed by the contract with the manufacturer, not by the Cosmetics Regulation. In white label, the adapted formulation remains with the manufacturer; in the case of a new private label development, formulation rights or exclusivity can be contractually transferred to the brand. It is advisable to specify before the start of the project which formulation data, test results, and documentation will be handed over upon termination. Confidentiality and formulation ownership are explored in depth in the magazine article “Confidentiality with the contract manufacturer: NDA and formulation ownership”.
Is it worth switching manufacturers in the middle of an ongoing project?
A switch is worthwhile if the reasons lie with the previous partner, such as a lack of in-house laboratory work or insufficient proximity to production, and cannot be resolved through agreements. Beforehand, it should be clarified which test results and documents will be handed over for the product information file; tests tied to the formulation, packaging materials, or manufacturing process may partially need to be repeated with the new manufacturer. The magazine article "Switching Cosmetics Manufacturers: How a Structured Transition Works" describes the process.
What is the minimum order quantity for the first production run at Labtree?
At Labtree, the minimum order quantity is generally 1,500 units per product. The exact quantity depends on the product type, fill size, and packaging. To learn what technically determines minimum quantities, check out our magazine article on MOQ in cosmetics.
