One of the questions we're asked most often is whether a product can be covered by a flexible Cosmetic Product Safety Report (CPSR). The answer isn't simply "yes" or "no", it depends entirely on the product, its ingredients, and the level of risk involved.

At Revega, we believe flexible CPSRs have an important place in the cosmetic industry. They make compliance more accessible for small brands, reduce unnecessary costs, and allow makers to continue creating products without needing a brand-new safety assessment every time they want to change a fragrance or swap one cosmetic-grade supplier for another.

However, flexibility should never come at the expense of product safety. A good flexible CPSR should be based on sound scientific reasoning, appropriate supporting data, and clear limits on what can and cannot be changed.

Products that are suitable for flexible CPSRs

Some products naturally lend themselves to a degree of flexibility because they are relatively low risk, have well-understood formulations, or have a long history of safe use.

Examples include:

• Bath bombs

• Bubble bars

• Bath salts

• Cold process soap

• Melt and pour soap

• Whipped soap

• Sugar and salt scrubs

• Anhydrous body butters

• Lip balms

• Solid perfume balms

• Oil-based perfumes

• Massage oils

• Body oils

These products either contain little or no water, or have a formulation that presents relatively few variables when ingredients are substituted within defined limits. Where appropriate, flexibility can often be achieved by allowing different fragrances, colourants, botanicals or cosmetic-grade oils, provided these remain within the boundaries of the assessment.

Products where flexibility is possible, but more limited

Some products can still be assessed flexibly, but only where there is suitable evidence to support it.

Shower gels, body washes and similar rinse-off products are a good example. Because these contain water and preservatives, changing ingredients has a greater potential to affect stability and preservation.

Where a formulation has undergone suitable preservative efficacy (PET/challenge) testing and stability testing, it may be possible to permit carefully controlled substitutions. These assessments are typically more restrictive than those for anhydrous products, with defined ingredient options and concentration limits based on the available evidence.

Similarly, lotions, creams and conditioners can often be assessed flexibly when they are based on a commercially manufactured cosmetic base that has already undergone extensive stability and preservative testing. In these cases, flexibility usually relates to adding approved fragrances, colourants or limited quantities of compatible additives that have been considered during the assessment.

Products that require custom non-flexible reports

There are situations where a flexible CPSR simply isn't the right approach.

Products containing multiple active ingredients, high-performance skincare formulations, anti-ageing products, exfoliating acids, peptides, retinoids, high levels of vitamins, complex botanical systems or other specialist actives should generally be assessed individually.

In these formulations, even relatively small changes can significantly affect product safety, stability or performance. Different active ingredients may interact with one another, alter the effectiveness of preservatives, change the pH of the formulation, or affect the stability of emulsions. The exact packaging may also become much more important, as migration of substances from packaging materials, oxygen permeability, UV protection and compatibility with the formulation can all influence product safety and shelf life.

In these circumstances, the safest and most scientifically robust approach is to assess each finished formulation individually, taking into account:

• The exact ingredient composition.

• Ingredient interactions.

• Stability data.

• Preservative efficacy.

• Packaging compatibility.

• Migration considerations where appropriate.

• Intended use and exposure.

This level of precision simply cannot be achieved through a highly flexible assessment.

Another common misconception is that a flexible CPSR means any packaging can be used. This is not the case.

Flexible assessments generally assume the use of cosmetic-grade inert packaging materials such as PET, HDPE, LDPE, PP, cosmetic-grade glass or appropriately coated aluminium, supported by suitable supplier documentation confirming their suitability for cosmetic contact.

If a manufacturer wishes to use unusual packaging materials, refill systems, metal containers without suitable internal coatings, airless systems with unknown components, or packaging that may interact with the formulation, additional compatibility work may be required.

A flexible CPSR should never exist simply to make life easier.

Its purpose is to provide sensible flexibility where scientific evidence shows that changes can be made without compromising consumer safety.

Where that evidence exists, flexibility can reduce waste, lower costs and make compliance far more practical for small cosmetic businesses.

Where the science doesn't support flexibility, every formulation deserves its own assessment.

Ultimately, a good assessor doesn't ask, "How flexible can we make this?"

They ask, "How flexible can we make this whilst still being able to confidently demonstrate that the product remains safe?"

That's the balance we want with producing CPSRs.  

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