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Combining cosmetics and supplements: skincare from outside, nutrients from inside
Skin can be supported from two sides: with skincare from the outside and with nutrients from the inside. At Novogenia, both products come from one saliva sample – day serum, night serum and body lotion from the cosmetics factory, personalized supplements from the supplement factory in the same building. Legally, they remain two worlds: cosmetics follow Regulation (EC) No 1223/2009, supplements follow food law with its authorized health claims. For skin, such claims exist, for example “Zinc contributes to the maintenance of normal skin.” Use them in their official wording and only for the supplement.
Two routes to the skin
Researchers analyzed data from 4,025 women aged 40 to 74 from a large US health survey. Dermatologists had examined their skin, and their diet over the previous 24 hours was recorded. The result: women with higher vitamin C intakes from food were less likely to have a wrinkled appearance and less likely to have age-related skin dryness. Higher linoleic acid intakes were also linked to less age-related dryness. These associations held after the researchers accounted for age, sun exposure, body weight and other factors (Cosgrove et al., American Journal of Clinical Nutrition, 2007).
A review from New Zealand explains why vitamin C in particular is so closely tied to skin: normal skin contains high concentrations of it, and it stimulates collagen formation and assists antioxidant protection against light damage. The authors compare both routes – supply through the diet and application to the skin (Pullar et al., Nutrients, 2017).
From this, a simple picture emerges: the skin has two entrances. Skincare reaches it from the outside, and nutrients from food and supplements reach it from the inside. An offer that uses both entrances is closer to how skin really works. Just do not mix up one thing: an observational study on diet is not an efficacy promise for a product. What you may advertise is governed by law – separately for each entrance.
One saliva sample, two products
At Novogenia, both start with the same saliva sample. The lab analyzes it in 4 days. A gene only makes it into the analysis if at least three independent studies support its effect. Two products come from the result:
- From outside: day serum, night serum and body lotion. The genetic result determines which active ingredients go into the formula and at what dosage.
- From inside: personalized supplements in daily sachets; one delivery lasts 90 days. Alongside the genes, a questionnaire and, where available, blood values feed into the formula.
Both adjustments are logical conclusions from the genetic profile. The genetic traits themselves are well documented. That a formula derived from them has a specific effect has not been confirmed in dedicated studies for every gene. Say so openly – it makes your offer more credible, not weaker. How genes become skincare is shown in Personalized cosmetics.
Two products, two legal worlds
Serum and supplement may sit in the same package, but legally they belong to different worlds:
| Question | Cosmetics: serum and lotion | Food supplement |
|---|---|---|
| What it is | substances or mixtures placed in contact with external parts of the body such as the skin, to clean them, protect them, change their appearance or keep them in good condition (Regulation (EC) No 1223/2009, Article 2) | foods intended to supplement the normal diet (Directive 2002/46/EC) |
| Before sale | responsible person (Article 4), safety assessment with safety report (Article 10), product information file (Article 11), electronic notification to the European Commission (Article 13) | depending on the country, a notification to the authority |
| Claims | no implied characteristics or functions the product lacks (Article 20); six common criteria of Regulation (EU) No 655/2013 | only authorized health claims (Regulation (EC) No 1924/2006) |
| At Novogenia | Novogenia takes on the role of responsible person; manufacturing to ISO 22716 | manufacturing under ISO 22000:2018; in most cases Novogenia handles the notification or supports you with it |
The six criteria for cosmetic claims are: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. More in Advertising cosmetics and Responsible person, safety assessment, notification.
Which skin topics can be supported from the inside
For skincare from the outside, every topic of the skin analysis helps decide which active ingredients go into the day serum, night serum and body lotion, and at what dosage. For supplements from the inside, the question is different: is there an authorized claim for the matching nutrient?
| Topic of the skin analysis | Nutrients with an authorized claim | Good to know |
|---|---|---|
| Collagen breakdown (MMP1) and collagen production | vitamin C (collagen formation for the normal function of skin) | Gene story: Collagen production |
| Oxidative stress (SOD2, GPX1, NQO1) | vitamin C, vitamin E, selenium, zinc, copper, riboflavin, manganese (protection of cells from oxidative stress) | Gene story: Oxidative stress |
| Selenium (GPX1) | selenium (protection of cells from oxidative stress; maintenance of normal hair and nails) | Gene story: Selenium |
| Coenzyme Q10 (NQO1) | none: the list of authorized claims has no entry for coenzyme Q10 | offer it without health-related advertising |
| Hydration | no specific claim; general skin claims exist for biotin, niacin, vitamin A and zinc, for example | hydration is mainly a topic for skincare from the outside |
| Tendency toward inflammation (TNF-α, IL6) | no suitable claim | statements about inflammation belong in no advertising |
| UV protection (MC1R) | none | Neither skincare nor supplements replace sun protection. |
The authorized health claims for skin, word for word
The list of authorized health claims is set out in Regulation (EU) No 432/2012. For skin, the consolidated version of 20 August 2025 reads:
| Nutrient | Authorized claim |
|---|---|
| Biotin | “Biotin contributes to the maintenance of normal skin” |
| Iodine | “Iodine contributes to the maintenance of normal skin” |
| Niacin | “Niacin contributes to the maintenance of normal skin” |
| Riboflavin (vitamin B2) | “Riboflavin contributes to the maintenance of normal skin” |
| Vitamin A | “Vitamin A contributes to the maintenance of normal skin” |
| Zinc | “Zinc contributes to the maintenance of normal skin” |
| Vitamin C | “Vitamin C contributes to normal collagen formation for the normal function of skin” |
| Copper | “Copper contributes to normal skin pigmentation” |
For oxidative stress, there are claims such as “Selenium contributes to the protection of cells from oxidative stress,” in the same form for vitamin C, vitamin E, zinc, copper, riboflavin and manganese. For hair, there is for example “Biotin contributes to the maintenance of normal hair.” Three rules keep you on the safe side:
- Meet the condition: each claim may only be used for a product that is at least a source of the nutrient as defined in the Annex to Regulation (EC) No 1924/2006.
- Do not bend the wording: “contributes to the maintenance of normal skin” does not become “rejuvenates” or “firms.” The safest choice is to use the official wording unchanged.
- Only for the supplement: the claims apply to foods. For serum and lotion, the Cosmetics Regulation applies – and under point 2 of the Annex to Regulation (EU) No 655/2013, a claim about an ingredient must not imply that the finished product has the same properties when it does not.
All rules for food advertising are explained in Health claims: what you may advertise in the contract manufacturing guide.
Well phrased: examples for a combined offer
| Better | Problematic | Why |
|---|---|---|
| “Zinc contributes to the maintenance of normal skin.” (for the supplement) | “Inside and out against skin aging” | an anti-aging promise that goes beyond the authorized claim |
| “Vitamin C contributes to normal collagen formation for the normal function of skin.” (for the supplement) | “The serum with vitamin C boosts your collagen production.” | transfers the food claim to a cosmetic; an efficacy claim about the serum needs its own evidence |
| “Which active ingredients go into your serum, and at what dosage, depends on your genes.*” | “The serum makes up for your defective genes.” | cosmetics do not change genes; the formula is a logical conclusion |
| “Selenium contributes to the protection of cells from oxidative stress.” | “Selenium protects your skin from inflammation.” | disease-related and not authorized in this form |
* With a note: the genetic traits are backed by studies; the formula derived from them is a logical conclusion, not scientifically proven.
From a single source: supplements and cosmetics under one roof
Two products do not mean two suppliers. In Eugendorf near Salzburg, the genetic lab, the supplement factory and the cosmetics factory share one building; the personalized cosmetics are formulated and filled separately in our own cosmetics production. For you, this means:
- One contact for formulation, branding and production of both products.
- One brand: supplements and cosmetics as white label under your name.
- One route: the saliva sample becomes a finished product without ever leaving the company or the EU.
- Certified quality: ISO 22716 (good manufacturing practice for cosmetics), ISO 22000:2018 (No. 00521/0) and ISO 9001:2015 (No. 14365/0), all certified by Quality Austria. Certificates are available on request (Quality assurance).
How personalized supplements are made is described in the contract manufacturing guide, for example in Manufacturing personalized supplements. The offer at a glance: White label for personalized supplements and cosmetics.
How to build a combined offer
| Format | Content | Rhythm |
|---|---|---|
| Skincare starter | skin analysis, results conversation, day serum, night serum and body lotion | one-off, with reorders |
| Outside and inside | plus personalized supplements | supplements every 90 days |
| Subscription with check-in | both products, plus a regular consultation | quarterly, matching the 90-day delivery |
The table is a model, not a fixed package list. The combination is especially natural in spas and wellness hotels: the skincare is part of the treatment, and the supplements follow as a takeaway or subscription after the stay (Selling cosmetics). Start small: white-label cosmetics are available from small batches, supplements from a single unit. How to plan recurring orders is shown in Subscription models.
Checklist: combining cosmetics and supplements
- Both products are cleanly separated in legal terms: Cosmetics Regulation here, food law there.
- For the supplement, only authorized claims in their official wording are used, and the conditions are met.
- No food claim migrates onto the serum or lotion.
- No word about preventing, treating or curing skin diseases, no anti-aging promise.
- Gene-based formulas are labeled as logical conclusions.
- Package and rhythm defined, for example quarterly to match the 90-day delivery.
- Consent and data protection for the genetic analysis settled (Genetic data and the GDPR).
Frequently asked questions
May I advertise a supplement with skin-related claims?
May I use the health claims for the serum as well?
Can a supplement be a cosmetic product?
Do I need two manufacturers for cosmetics and supplements?
Does the genetic analysis shape both formulas in the same way?
Related: White label: personalized supplements and cosmetics · Health claims: what you may advertise · Advertising cosmetics: what is allowed
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Request a project →Discover BeautyMeNote: This guide is general information for businesses and professionals and does not replace legal advice. BeautyMe products are cosmetic products; statements in this guide are not promises of cure. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations for skincare and formulation derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.