Cosmetic Product Development: From Brief to Approved Formula
Quick answer
Cosmetic product development turns a brand's brief into one approved, version-numbered formula that a factory can reproduce. It runs through six checkpoints: brief, feasibility, coded samples, packaging in parallel, formula freeze and handover. Each one ends with a decision to continue or go back.
- Start with: a one-page brief that separates what must not change from what can
- Decide early: ready base, adapted formula or custom development
- Compare samples: by code and version, under the same conditions, with written feedback
- Bring the real container: the formula and the pack are approved together
- Freeze means: an agreed version and specification, not that all safety work is done or the product is cleared for sale
- Scope: skincare, hair and body care developed with an ODM partner, ending at the handover to production. Men's grooming, ingestible beauty supplements and massage creams are not covered
Product development in the cosmetics industry is mostly decision management: many small choices, made in order and written down. This guide walks through the cosmetic product development process for brand owners and product or sourcing managers who have already chosen a development partner. If you are still comparing labs, start with how to verify formulation capability. What happens after the formula is approved, from pilot batch to batch release, is covered in our cosmetic manufacturing process guide.
Step 1: Write a One-Page Brief
A good brief is short enough that both sides read all of it. One page is enough if every field is filled in and each line is marked as a must or as flexible.
| Field | What to write | Usually |
|---|---|---|
| Product type and use | Leave-on or rinse-off, face, body or hair, how often it is used | Must |
| Target markets | Every country you plan to sell in, including later ones | Must |
| Intended claims | The exact wording you want on pack and online | Must, wording may change |
| Reference product | A product to compare against, and which part of it you like | Flexible |
| Texture and skin feel | Thickness, spread, finish, tackiness, absorption | Must for the core feel |
| Fragrance and colour | Fragrance-free, light, or a direction; any colour limits | Often flexible |
| Ingredient rules | Hero ingredients, ingredients to avoid, vegan or other positioning | Must |
| Packaging | Format, material, dispenser, fill size, and whether it is already chosen | Must once chosen |
| Target cost and first order | Unit cost target and planned first quantity | Range |
| Launch date | The date you are working back from | Flexible if stated honestly |
The must and flexible marks do most of the work. When requirements later conflict, the developer knows which one to protect without asking you every time.
Step 2: Confirm Feasibility Before the First Sample
The first reply to a brief should be a feasibility check, not a sample. It answers three questions: can the musts be met together, what does each market or claim require, and which route fits.
Conflicts are normal. A very light gel with a high oil load, a "fragrance-free" product with a strong raw-material odour, or a pump that cannot dispense the thick texture you want. Each conflict should be written down with an owner and a decision: change a flexible item, accept a compromise, or test both options as separate sample versions. A conflict without an owner tends to come back at the freeze stage.
The three routes:
- Ready base. An existing formula with small changes, such as fragrance or colour. Fewest unknowns, least room for differentiation.
- Adapted formula. An existing formula reworked for a new texture, active or pack. Useful when a base is close but one must is missing.
- Custom development. A new formula built from the brief. Most room to differentiate, and the most rounds and checks. This is the route our ODM service is set up for.
The route also changes what you pay for. What is usually included and what is not is covered in our skincare formulation cost guide.
Step 3: Compare Samples Under the Same Conditions
Sample feedback is only useful if every reviewer judges the same thing in the same way. Agree on the conditions before samples go out:
- The same amount, the same application area and the same time after application for every reviewer.
- Room temperature samples, opened at the same time, compared side by side with the reference.
- Written feedback on the same form, filed under the sample code, not in a chat thread.
Every sample carries a code that combines the project and the version, and every version has a one-line change note. The example below is illustrative, not a client record.
| Sample code | Change from previous | Feedback (illustrative) | Decision |
|---|---|---|---|
| P-001 v1 | First version from brief | Spreads well, finish slightly tacky | Revise |
| P-001 v2 | Tack reduced, fragrance unchanged | Finish acceptable, fragrance too strong | Revise |
| P-001 v3 | Fragrance lowered, filled in chosen pump | Meets brief, pumps cleanly | Candidate to freeze |
A practical feedback form has a few fixed rows: sample code, reviewer, date, conditions, texture, spread, finish, fragrance, skin feel after a set time, and one line "keep / change". Change one or two things per round. Changing five at once makes it hard to tell which change caused which result.
Step 4: Develop the Formula and the Packaging Together
Send the real container, or the closest production-grade sample, as soon as the pack is chosen. A formula approved in a glass jar is not automatically approved in an airless pump or a tube. Viscosity has to suit the dispenser, the formula has to suit the materials, and the pack can affect stability.
The EU guidelines on the safety report make the same point. They quote the SCCS recommendation that physical stability tests are carried out with inert containers and with those intended to be used on the market (Commission Implementing Decision 2013/674/EU, section 3.2.3). Annex I of Regulation (EC) No 1223/2009 also asks for the relevant characteristics of the packaging material, in particular purity and stability. This is law for products sold in the EU, and good practice elsewhere.
Review the test plan again when any of these change: container material, dispenser type, closure or liner, fill size, or the supplier of a pack component. How compatibility is tested is covered in packaging compatibility testing for pumps, droppers and airless.
The Development Checkpoint Table
| Checkpoint | Brand provides | Developer provides | Who confirms | Continue if / return if |
|---|---|---|---|---|
| 1. Brief | One-page brief, must and flexible marks | Questions on missing fields | Brand product owner | Continue when every must is defined; return if markets or claims are open |
| 2. Feasibility | Decisions on named conflicts | Route proposal, conflict list, likely test needs by market | Both | Continue when each conflict has a decision; return if a must cannot be met |
| 3. Samples | Written feedback per sample code | Coded samples with change notes | Brand reviewers | Continue when one version meets the musts; return if feedback cannot be traced to a code |
| 4. Packaging | Real or production-grade container | Sample filled in that pack, updated test plan | Both | Continue when the candidate works in the chosen pack; return if the pack changes |
| 5. Formula freeze | Signed approved sample | Version number, specification, test status list | Both, in writing | Continue when the same version is signed by both; return if open items block it |
| 6. Handover | Final artwork inputs, order plan | Development pack for production | Developer and production | Continue when the pack is complete; return on any change to formula or pack |
Step 5: Freeze the Formula
Formula freeze is the point where both sides agree that one version is the product. It should leave a short record:
- Version number of the approved formula, matching the sample code.
- Signed approved sample, with a retained reference kept by both sides.
- Specification for the parameters to be checked, such as appearance, odour, pH and viscosity where relevant.
- Test status for each agreed test: done, running or not started, with the pack it was run in.
- Open items with an owner, for example a running stability study or a claim still under review.
Freeze is not the same as finished. It does not mean all safety evidence is complete, that claims are substantiated, or that the product can be sold. In the EU, for example, the safety report needs evidence that the composition tested for stability corresponds to the product actually placed on the market (2013/674/EU, section 3.2.3). That is one reason the version number matters. Which tests your markets need is covered in cosmetic safety testing and cosmetic stability testing.
Step 6: Hand Over a Complete Development Pack
The handover pack is what production works from. A practical list:
- Approved formula version and full composition, with raw material grades where the grade matters
- Finished-product specification
- Signed approved sample and its retained reference
- Packaging specification for every component, matching what was tested
- Test status list and open items with owners
- Claims agreed for the label, and the target markets
- Development notes that matter for scale-up, such as order of addition or temperature-sensitive steps
From here the formula enters the steps described in our manufacturing process guide.
What Reopens an Approved Formula
After freeze, any change becomes a new version that needs its own approval. Treat these as triggers to check again:
- A raw material supplier or grade change, including fragrance
- A change to the composition, however small
- A container, dispenser, closure or material change
- A new market, a new claim or a change in the conditions of use
- A change in the rules on an ingredient in the formula
This is not only good practice. The EU guidelines say the safety assessment should be reviewed and, if necessary, updated when the formulation or raw material specifications change, when the conditions of use change, or when the rules on an ingredient change (2013/674/EU). How change approval is written into the contract is covered in our cosmetic manufacturing agreement guide.
Have a brief ready, or half ready?
Send your brief, target markets and packaging. We will mark which requirements conflict, suggest a route, and say which tests your markets are likely to need before sampling starts.
Frequently Asked Questions
What are the stages of cosmetic product development?
A one-page brief, a feasibility check, coded sample rounds, packaging in parallel, formula freeze and a handover to production. Each stage ends with a decision to continue or go back, and the result is one approved formula version with a specification and a list of open items.
What should a cosmetic product brief include?
Product type and use, target markets, intended claims, a reference product, texture, fragrance and colour, ingredient rules, packaging, target cost and first order, and the launch date. Mark each line as a must or as flexible so conflicts can be decided quickly.
How many sample rounds does product development take?
There is no fixed number. It depends on the route, how clear the brief is and how many changes are made per round. Changing one or two things per round and filing feedback under the sample code usually keeps the number of rounds down.
Does an approved formula mean the product is ready to sell?
No. Formula freeze is an agreement on one version and its specification. Safety assessment, stability work in the final pack, claim support and market notification can still be open, and each market has its own requirements.
When does a formula change need to be approved again?
Whenever the composition, a raw material supplier or grade, the packaging, the claims, the markets or the conditions of use change. Each change creates a new version, and the affected tests and safety assessment should be checked again.
Sources
- Commission Implementing Decision 2013/674/EU, guidelines on Annex I to Regulation (EC) No 1223/2009, section 3.2.3 on stability and the section on updating the safety report
- Regulation (EC) No 1223/2009, Annex I, consolidated version of 18 May 2026, on packaging material characteristics
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