Business and Regulatory · CPSR ·

A CPSR Doesn't Judge Your Formula – It Assesses Its Safety

One of the biggest misconceptions we see in the cosmetic industry is the belief that receiving a Cosmetic Product Safety Report (CPSR) means your formulation has somehow "passed" an expert assessment and is therefore a well-designed, high-quality cosmetic product.

It doesn't.

A CPSR is a safety assessment, not a formulation assessment.

Understanding the difference is one of the most important things you can learn as a cosmetic formulator.

What Does a CPSR Actually Assess?

A CPSR exists to determine whether your finished cosmetic product is safe for the consumer when used as intended.

The safety assessor considers factors such as:

  • The ingredients you've chosen.

  • The concentration of each ingredient.

  • Toxicological data for those ingredients.

  • The intended area of application.

  • Consumer exposure.

  • Margin of Safety (MoS) calculations where required.

  • Compliance with cosmetic legislation.

  • The microbiological and stability information provided.

The assessment answers one question:

"Is this product considered safe for its intended use?"

It does NOT answer questions such as:

  • Is this a good formulation?

  • Will it perform well?

  • Will customers like it?

  • Will it remain stable for two years?

  • Does it feel nice on the skin?

  • Will it separate after three months?

  • Is this the best preservative system?

  • Could the formulation be improved?

Those are formulation and product development questions, not safety assessment questions.

Safety and Quality Are Two Different Things

A product can be perfectly safe but still be a poor cosmetic product.

For example, a cream may:

  • Feel greasy.

  • Be difficult to spread.

  • Separate after several weeks.

  • Become rancid because no antioxidant was included.

  • Be overly thick or too thin.

  • Lose its fragrance quickly.

None of these automatically make a product unsafe.

They make it a poorly performing or unstable formulation.

Likewise, an excellent formulation can still fail a safety assessment if ingredients exceed legal limits or exposure calculations show an unacceptable risk.

Safety and formulation quality are related—but they are not the same thing.

Where Many Beginner Formulators Go Wrong

One pattern we see regularly is enthusiastic beginners creating their first formulations by:

  • Following a YouTube video.

  • Copying a blog recipe.

  • Combining ingredients they like.

  • Mixing together several recipes they've found online.

  • Assuming that if each ingredient is "good", the finished product must also be good.

Unfortunately, formulation isn't that simple. Every ingredient affects every other ingredient in the formula.

Changing one ingredient can alter:

  • Stability.

  • Viscosity.

  • Preservation.

  • Emulsion structure.

  • Product feel.

  • Shelf life.

  • Packaging compatibility.

This is why cosmetic formulation is both a science and an art.

We Often Give Extra Advice (Even Though It's Not Our Job)

Although our role is to provide a safety assessment, we genuinely want our customers to succeed.

If we notice something obvious while reviewing a formulation, we'll often mention it.

For example, we may suggest:

  • Adding an antioxidant to an oil-rich formula that is likely to oxidise over time.

  • Reviewing the preservative choice or usage rate.

  • Looking at the emulsifier system.

  • Considering a chelating agent.

  • Correcting an obvious formulation issue that could affect stability.

These comments are not technically part of the CPSR itself—they're simply additional guidance based on formulation experience.

We'd much rather help someone improve a product before they spend time and money manufacturing it.  We may offer formulation services in future to help further with this.

Stability Testing Isn't Optional

One answer on our CPSR orders questions always catches our attention.

"Have you completed stability testing?"

Every so often the answer is simply:

No.

Or sometimes:

I don't know how.

We completely understand that many new formulators are still learning.

However, stability testing is not optional.

A CPSR relies on information provided by the responsible person, including evidence that the product remains stable throughout its intended shelf life.

Without proper stability testing, nobody truly knows how the product behaves over time.

Will it separate?

Will it discolour?

Will the fragrance fade?

Will the preservative remain effective? (this requires PET testing)

Will the packaging interact with the formulation?

These are all questions that stability testing helps answer.

Even after your product goes on the market, stability should continue as part of good manufacturing practice and ongoing product quality monitoring.

We'll be covering stability testing in much greater detail in a dedicated video soon.

A CPSR Isn't a Gold Star

Receiving your CPSR doesn't mean your product has been awarded a certificate for excellent formulation.

It simply means that, based on the formulation submitted and the supporting information provided—including stability information—the product is considered safe for consumer use when used as intended.

Those are two very different things.

Our Advice to New Formulators

If you're just starting out, don't rush.

Take the time to understand:

  • Why ingredients are included.

  • How emulsions work.

  • Preservation.

  • Oxidation.

  • Stability.

  • Manufacturing techniques.

  • Packaging compatibility.

The better your formulation knowledge becomes, the better your products will be.

Why We Created Our Pre-Assessed Flexible CPSRs

This is exactly why we developed our pre-assessed flexible CPSRs.

Rather than starting from scratch with a custom formulation before you've built confidence and experience, our flexible formulations provide a reliable framework that has already been professionally developed and assessed.

They still allow you to personalise your products through carefully controlled ingredient options, fragrances and additives, giving you plenty of room for creativity while reducing many of the common formulation mistakes beginners make.

They're also considerably more cost-effective than commissioning multiple custom CPSRs while you're still learning.

That said, even with a professionally developed base formulation, you should always carry out your own stability testing using your exact ingredients, manufacturing process and chosen packaging. Small variations in raw materials, processing methods and packaging can all influence the long-term stability of the finished product.

Think of a pre-assessed formulation as a strong foundation—not a replacement for good manufacturing practice.

A CPSR is one piece of the admin.

It confirms that a cosmetic product is considered safe for its intended use.

It does not tell you whether you've created a beautiful, elegant, stable or commercially successful formulation.

Those things come from education, experience, careful testing and continuous improvement.

So if you're new to formulation, give yourself permission to slow down.

Learn the science. Test thoroughly. Keep improving.

You can find our pre-assessed CPSR options HERE

Back to Blog