From your formula to a signed file

We work out what your product legally is, then ask only for what is missing.

First we work out what your product legally is — a cosmetic, or something else. A biocide or a medicine is a different regime with different rules, and we will not write a cosmetic safety report for one.

Then we send you a document request written for your product. If your gel needs a preservative-efficacy test, it is on the list; if it does not, it is not there. We never quote a requirement to your manufacturer from memory — only from the official register, with the source next to it.

Your recipe broken down to single ingredients and checked against the EU's restricted lists.

We take your recipe apart until every line is a single ingredient with a percentage next to it. Blends get opened up too. Where a supplier will not say what is in a material, we record that it is unknown rather than guessing.

That list is then checked against the EU's lists of prohibited and restricted ingredients (Annexes II–VI, Art. 14), using the versions in force on the date you plan to start selling — not today's, if those differ.

We also build the ingredient list for your label in the descending order of weight the law requires (Art. 19(1)(g)), and read your marketing copy against the six rules the EU sets for cosmetic claims (Reg. (EU) 655/2013).

The evidence half of the safety report, built from a recipe that is now locked.

Part A is the evidence — every piece of safety data about what is in your product, and how much of it a person is exposed to (Art. 10(1)). Before we start, the recipe is locked, so the report cannot end up describing a version you have since changed.

Every scientific figure in it is a line a person has checked. Software drafts the text from that locked set of figures, and a second pass deletes any sentence that cannot be traced back to one. Software drafts; a pharmacist signs.

The verdict half, signed by a named pharmacist once nothing is outstanding.

Part B is the verdict — the judgement that the product is safe to use, which is the part that carries a signature. It is signed by David Vandevoort, pharmacist (Master, KU Leuven; PhD, KU Leuven 2010). The law says this has to be signed by someone holding a named qualification (Art. 10(2)), and pharmacy is on that list.

The signature only comes after the file is complete: every ingredient identified, every piece of safety data confirmed, the safety margin worked out — the gap between how much a person absorbs and how much is known to be harmless — and the register checked by a person rather than a script. When something is still outstanding, it is almost always one document, and we tell you which one.

We keep the file, and reopen it if the law it relies on changes.

We keep the file

We assemble the file with a contents page, a fingerprint for every document so you can show none of them were altered afterwards, and a written list of anything still missing. It has to be kept for ten years after the date on which the last batch was placed on the market (Art. 11(1)).

We also fill in the EU notification, which goes on the Commission's cosmetics portal (CPNP) before the product goes on sale (Art. 13(1)). Submitting it is the Responsible Person's act — so we do it if you have appointed us, and you do it if you have not.

We watch the law

After that, we re-read the EU register every day. This part does not depend on who the Responsible Person is — it runs while we hold your file, whether the role is ours or yours.

Nothing is acted on automatically. A register change becomes something we act on only once a person here has read it and accepted it under their own name, so you are never chased about a rule a script misread overnight. When an accepted change touches one of your products, we screen that product again and write to you with what it means for it — including whether the safety assessment has to be reopened. Being told is part of what you already pay; reopening the assessment, if it is needed, is a separate line.