Services  /  Cosmetics safety
03 / Pillar

Cosmetics safety.

Cosmetic Product Safety Reports, ingredient safety assessments and SCCS-style review of finished products — signed off as a qualified Safety Assessor for both EU and UK markets, and structured so your Responsible Person can respond to authority questions with the reasoning already in place.

Cosmetic formulation under safety review
Frameworks
EU 1223/2009
UK Cosmetics Regs
SCCS NoG 12
Categories
Skincare · Haircare
Make-up · Sun · Oral
Tooling
MoS modelling
SED · PDE · HRIPT
Outputs
CPSR Part A + B
Ingredient SA · Claims
What we do
A safety file the Responsible Person can defend.

The Responsible Person carries the legal liability — not the assessor, not the brand, not the contract manufacturer. We structure every file around the questions a market-surveillance authority opens a CPSR to ask.

Reviewer question 01
Ingredient safety
Is each ingredient assessed at its in-use concentration — not at a generic SCCS opinion level?
Reviewer question 02
MoS traceability
Can each MoS be reconstructed from NOAEL, retention factor, SED and assessor reasoning?
Reviewer question 03
Foreseeable use
Are vulnerable subpopulations, misuse and aggregate exposure scenarios addressed explicitly?
Reviewer question 04
Part B specificity
Is the Part B reasoning specific to this product and this formulation?
Make-up product range under safety assessment

From ingredient dossier to Part B sign-off — the same reasoning, applied at every concentration and product format.

EU 1223/2009 · SCCS NoG 12 · UK Cosmetics Regulation
Scope of support

Where we step in.

From ingredient triage at formulation through to SCCS opinion response — concrete points across the lifecycle where senior cosmetic-safety input shapes the file.

Cosmetic ingredient laboratory testing

From formulation triage to SCCS opinion response — safety assessments structured to hold up under market-surveillance review.

CPSR Part A · Part B · PIF · CPNP
01
Portfolio screening
Early-stage screening of actives, fragrances and naturals against EU/UK restrictions, CLP CMR status, SCCS opinions and ECHA SVHC lists — surfacing data gaps and assessment vulnerabilities before formulation locks in.
Annex II-VI · CLP CMR · SCCS · SVHC
02
Hazard ID & PoD selection
Systematic evaluation of toxicological datasets to identify critical endpoints and points of departure (NOAEL, BMD / BMDL or alternative metrics), with transparent justification consistent with SCCS practice.
SCCS NoG · BMD
03
Systemic exposure & MoS
SED, NOAEL and retention factor modelling per ingredient — with explicit reasoning on dermal absorption defaults vs. measured data, and specific assessment for vulnerable subpopulations (children, pregnant users, sensitive or compromised skin).
SED · SCCS NoG · MoS · Children < 3
04
Endocrine activity assessment
Weight-of-evidence evaluation of endocrine activity (estrogenic, androgenic, thyroid) — distinguishing hazard signals from biologically relevant adversity at cosmetic exposure levels.
WoE · SCCS · EATS
05
Data gap management
Scientifically robust read-across and weight-of-evidence strategies to address gaps on systemic endpoints, supported by structural similarity, toxicokinetic considerations and mechanistic plausibility.
RAAF · WoE · toxicokinetics
06
NAMs & NGRA integration
Integration of NAM-derived evidence and NGRA concepts where appropriate, including in vitro bioactivity data, in silico predictions and exposure-led reasoning, applied within structured weight-of-evidence frameworks.
NAMs · NGRA · IATA
07
SCCS-aligned safety dossiers
Preparation of SCCS-compliant safety dossiers for ingredients under expert review, addressing the Notes of Guidance with hazard characterisation, exposure assessment, uncertainty analysis and clear conclusions structured for SCCS format and expectations.
SCCS NoG · ingredient dossier
08
CPSR & PIF preparation
Cosmetic Product Safety Reports (Part A and Part B), Product Information Files and supporting documentation prepared and maintained in line with EU and UK requirements, including qualified Safety Assessor sign-off on Part B for both markets.
CPSR Part A · Part B · PIF · SCCS NoG 12
09
Notification
CPNP (EU) and SCPN (UK) notification support, including INCI ordering, frame-formula selection and CMR / nanomaterial declarations.
CPNP · SCPN · OPSS
10
SCCS opinion response
Scientific positioning and response support for SCCS opinions, comments, clarifications or requests for additional justification, including preparation of supplementary dossiers and structured technical responses.
SCCS
11
Regulatory intelligence
Ongoing monitoring of SCCS opinions, ingredient restrictions, emerging scientific issues and regulatory developments, with clear interpretation of relevance to client portfolios.
SCCS · horizon scanning
When clients engage us

What prompts the call.

A cosmetic safety team reviewing a CPSR
The first conversation Most engagements begin with one product about to launch — or one ingredient that's just landed on an SCCS work programme.

Brand owners launching a new range who need a Safety Assessor on the file. Contract manufacturers needing CPSRs across a portfolio with consistent reasoning. Indie brands navigating UK SCPN alongside EU CPNP for the first time. We also support clients facing cosmetovigilance signals or market-surveillance correspondence.

Case study

Cosmetic ingredient, DART data gap.

Anonymised engagement

A cosmetic ingredient under reformulation had no usable in vivo DART data — and animal testing was not an option under EU Cosmetics Regulation Article 18.

Challenge

No usable in vivo developmental and reproductive toxicity data, a strict animal-testing prohibition under Article 18, and a regulator-facing safety case that still had to stand on its own.

Approach

  1. 01
    NAM-based read-across to a structurally and metabolically related ingredient, with the read-across hypothesis documented against ECHA RAAF criteria.
  2. 02
    PBPK-informed IVIVE to derive internal exposure metrics — making the comparison between predicted internal dose and the analogue NOAEL, rather than topical applied dose.
  3. 03
    Weight-of-evidence integration of in vitro DART-relevant assays alongside the read-across and IVIVE strands.
  4. 04
    Exposure-led safety case compiled at realistic cosmetic use levels, with transparent uncertainty handling for SCCS-style review.

Outcome. DART data gap addressed without animal testing. Safety margin demonstrated using internal-dose comparison. SCCS submission supported by transparent NAM-based reasoning, with the NAM/PBPK framework reusable for related ingredients.

Questions we hear

Five questions, answered straight.

Most cosmetics conversations start in one of these five places. If yours doesn't fit, send it through anyway — we'd rather hear the question than guess at it.

1

Can you sign Part B as Safety Assessor?

Yes, for both EU and UK markets. The Article 10(2) competence requirements under EU 1223/2009 and the UK Cosmetics Regulation specify a university qualification in pharmacy, toxicology, medicine or a similar discipline. CPSRs are signed by senior toxicologists at NexGenTox holding qualifying degrees in pharmacology or toxicology, together with European Registered Toxicologist (ERT) credentials and over 20 years of cosmetic safety assessment practice. Sign-off includes MoS modelling, foreseeable use reasoning and assessor signature.

2

How do you handle fragrance in CPSRs?

Per IFRA standards and the 26 + 81 SCCS-listed allergens, with concentration-specific MoS and labelling assessment. Where IFRA certificates are missing or insufficient, we work with the supplier to obtain compliant documentation before sign-off.

3

How do you handle ingredients with endocrine concerns?

Through weight-of-evidence assessment of endocrine activity and adversity at realistic cosmetic exposure levels, following SCCS scientific reasoning. We distinguish hazard signals from biologically relevant effects, integrate in vitro mechanistic data with apical evidence where available, and document uncertainty transparently. The aim is a defensible position on whether endocrine activity translates into concern under intended cosmetic use, supported by structured documentation of activity, adversity and uncertainty.

4

How do you handle data-poor ingredients?

Through structured read-across, weight-of-evidence reasoning and NAM-derived evidence, applied within frameworks recognised by SCCS. Where ingredients lack conventional in vivo data, we build the safety case using analogue data, in silico predictions, in vitro bioactivity and, where useful, PBPK-informed internal exposure modelling — with uncertainty handled transparently rather than hidden in defaults.

5

Can you support an ingredient through SCCS review?

Yes. We prepare SCCS-compliant safety dossiers for ingredients under expert review, address Notes of Guidance requirements, and respond to SCCS comments, clarifications or requests for further justification with structured technical responses.

Start the conversation

One product. One range. One call.

Tell us the product, the market and the launch date. We'll come back with an initial scope and a fit assessment.