Making your own makeup is a creative and exciting activity. With pigments, oils and a few basic supplies, you can develop unique formulas at home that completely fit your style. Yet there is more to producing makeup than just experimenting with colors and textures. Once you want to share your creations with others or perhaps even sell them, you face strict regulations. That’s because in Europe, there are make-up regulations EU, which aim to ensure that all cosmetics on the market are safe.
Central to those regulations is the EU cosmetics safety assessment, also called CPSR (Cosmetic Product Safety Report). For foundations, this report is especially important because they are used daily and often come into prolonged contact with the skin. Thus, a foundations safety report is indispensable to legally market a product. In this article we look at why this report is so important, what role pigments play, what exactly is in a CPSR and how you as a DIY maker can take it into account.
Why foundations are assessed extra rigorously
Foundation and other makeup products are among the most sensitive categories within the cosmetics industry. Whereas a shampoo or shower gel is rinsed off after a few minutes, foundation often stays on the skin for eight to 12 hours a day. Moreover, it is used daily and always on the same areas of the face. This means that the skin is repeatedly exposed to the same ingredients for long periods of time.
This is precisely why EU makeup regulations set the bar high. The EU cosmetics safety assessment looks at factors such as duration of skin contact, frequency of use, size of application area and possible cumulative exposure over several years. It sounds stringent, but this approach protects consumers from irritation, allergies and adverse effects that might take a long time to appear.
Pigments: the core and the challenge
Pigments are indispensable in foundations and makeup. They provide color, coverage and often the visual character of the product. Yet they are also the biggest challenge when it comes to safety. Within makeup regulations EU, only pigments listed in Annex IV of Regulation (EC) No. 1223/2009 are allowed. Many pigments that can be used without problems elsewhere in the world are banned or subject to strict conditions in the EU.
On top of that, pigments can naturally contain impurities. Examples include traces of heavy metals such as lead, cadmium or mercury. These are not intentionally added, but come along as by-products in the production process. The EU cosmetics safety assessment requires that these impurities be reduced to a minimum. In a foundations safety report, a producer must be able to demonstrate that the values are “as low as technically feasible.” This is done with laboratory tests, batch analyses and certificates from suppliers.
For DIY makers experimenting at home, it’s therefore wise to always use pigments specifically for cosmetic use. At YouWish, you’ll find pigments that meet EU standards, so you can work on your own recipes without worry.
The foundations safety report in detail
A CPSR consists of two major parts. The first part contains all the information about the composition of the product. This describes the ingredients, their properties, microbiological stability and packaging information. For foundations, it is also essential to include exposure data. Think about how often the product is used, how much is applied at a time and on which parts of the face. So this first part is a comprehensive database that contains all the relevant details.
The second part of the report is written by a qualified safety evaluator. This may be a toxicologist or a pharmacist with recognized experience in cosmetics. This expert evaluates the information gathered and draws a conclusion about the safety of the product. Without this signed conclusion, the product is not allowed on the European market. A foundations safety report is thus the official confirmation that a product complies with make-up regulations EU and is safe for daily use.
Labeling and transparency
In addition to the contents of the product itself, the packaging is also important. Makeup regulations EU require that all ingredients must be listed on the label according to the INCI designation (International Nomenclature of Cosmetic Ingredients). Also, allergens that occur above certain values must be listed separately. For products with a shelf life of less than 30 months, an expiration date is mandatory; for all other products, a symbol indicating how long the product can be used after opening must be used.
A special rule applies to foundations and makeup with multiple shades. In this case, manufacturers are allowed to use the statement “may contain” followed by a list of pigments found in the different variants. This avoids having to print a separate label for each shade, while allowing consumers to clearly see which pigments may be in the product. This component is also part of the EU cosmetics safety assessment, as it directly contributes to transparency and safety for the user.
What DIY makers can do
For many DIY makers, this may sound overwhelming. After all, you want to be primarily concerned with developing beautiful colors and fine textures, not regulations. Still, there are ways to combine your creative process with the requirements of the law.
The first step is to work with ingredients that are safe and traceable. Pigments of cosmetic quality are essential, because only with them can you be sure that your formulas are in line with makeup regulations EU. In addition, it helps to keep good records of your recipes. Record quantities, ingredients and observations so that you can always look back and have a solid foundation should you ever have an official foundations safety report prepared.
Hygiene is another point that is often underestimated. Work clean, use distilled water and sterilize your tools. This will prevent microbiological problems and make it easier to later meet the requirements of an EU cosmetics safety assessment. Finally, it’s smart to test your batches for stability. See if the color or odor changes over time and note your findings. This may seem simple, but it is exactly this kind of data that a safety assessor needs.
A DIY inspiration: mineral foundation
To make this concrete, for example, you can try making a simple mineral foundation at home. Mix cosmetic micas, titanium dioxide and iron oxides to create a shade that matches your skin tone. Playing with the ratio will give you the right coverage and undertone. Want a little more care? Then add a drop of jojoba oil for better adhesion. Keep your mixture in a tightly sealed jar and test how it behaves on the skin.
This kind of experimentation gives you as a maker insight into how pigments work together and what effects you can achieve. But as soon as you want to use or sell these products outside your own bathroom, an official foundations safety report must be prepared. Only then will you meet the requirements of make-up regulations EU and be allowed to legally market your product.
CPSR requirements for foundations and makeup.
Part A: Product safety information
The Cosmetic Product Safety Report (CPSR) consists of two parts, with Part A focusing on collecting all product safety data. This includes:
- Full composition: both quantitative and qualitative breakdown of ingredients. For foundations, this usually means emulsifiers, humectants, preservatives and complex pigment mixtures.
- Physical and chemical properties: data on stability, solubility and possible interactions between ingredients.
- Microbiological quality: evidence that the product is resistant to microbial contamination throughout its shelf life and under normal use.
- Impurities, trace and packaging info: for pigmented products, this means testing for heavy metals such as lead, cadmium, arsenic and mercury, and checking that levels are within safe limits.
- Normal and foreseeable use: details of how often the product is applied, how much is used and the main routes of exposure.
Part A relies heavily on laboratory testing and accurate documentation. Especially for makeup products, skin exposure calculations are crucial, as these formulations remain on the skin for many hours at a time. Safety evaluators apply standard surface values from the Scientific Committee for Consumer Safety (SCCS) to confirm that the margin of safety remains acceptable to consumers.
Part B: Safety assessment and conclusion
Part B of the CPSR can only be completed by a qualified safety assessor, usually a toxicologist or pharmacist with recognized qualifications. Their role is to carefully review the data collected in Part A and provide a professional opinion on the safety of the product.
This evaluation covers critical issues such as whether heavy metal impurities are under control, whether repeated daily exposure remains within safe limits, and whether certain pigments in foundations may pose sensitization risks. The assessor’s signed conclusion provides the legal basis for the product’s market approval. Without a valid Part B, no makeup product can be legally placed on the EU market.
Frequently Asked Questions
Q1: Does each color foundation need its own CPSR?
Not always. One CPSR may be sufficient if the basic formula remains the same and only the pigments change. However, separate CPSRs are needed if pigments present new toxicological problems.
Q2: What does the phrase “May contain:” on a cosmetics label mean?
Without printing separate lists for each SKU, manufacturers can list possible pigments for all shades, providing transparency. The list is valid only if all pigments on the list are allowed by Annex IV.
Q3: Should foundations in the EU be tested for heavy metals?
Yes. Impurities in pigments must be kept “as low as technically feasible,” but intentional additions are prohibited. The CPSR provides for laboratory analysis.
Q4: Can my makeup product contain nanomaterials?
Yes, but only after it is specifically stated and marked as “(nano)”. According to SCCS guidelines, a thorough safety assessment is required.
Q5: How long should the product information file (PIF) be kept?
After the last batch of the product is placed on the EU market, the responsible person must keep the PIF for 10 years.
Conclusion
Making your own makeup is a creative journey where you discover colors, textures and formulas. But those who want to go a step further and share or sell their products must be mindful of the law. EU makeup regulations require that every product undergo an official EU cosmetics safety assessment and that a full foundations safety report is available.
This may sound complicated, but the goal is clear: to protect consumers and ensure the quality of cosmetics. For DIY makers, this means taking steps in the right direction even with your first experiments by working with safe ingredients, keeping careful records of recipes and working hygienically.
At YouWish, you’ll find pigments, oils and other DIY ingredients that comply with EU standards. So you can get creative while learning how to build your projects toward safe and compliant formulas. Explore our range of pigments, soap and cosmetic bases and fragrance oils and start creating makeup today that is not only beautiful, but also safe and responsible.
