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How to get cosmetics manufactured: the process from idea to launch

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 13 October 2026 · Reading time: 9 min

A serum needs more than a good formula

Imagine your formula is ready. The texture is right, the scent works, the label is printed. Can you start selling now? Not yet, not in the EU. Before the first bottle crosses the counter, the Cosmetics Regulation (EC) No 1223/2009 requires four things: a responsible person established in the EU, a safety assessment by a qualified expert, a product information file and an electronic notification (Art. 4, 10, 11 and 13).

Think of the product information file as an aircraft’s logbook. It records what is in the product, how it was made and why it is safe. And this logbook must remain available to the authorities for ten years after the last batch.

Sounds like a lot? It is – if you have to handle it alone. With a manufacturer that combines lab, production and the legal role under one roof, it becomes a clear process in six steps.

The six steps at a glance

1. Idea and route: target group, positioning and the right partner model.
2. Formula or base: proven base formulation or your own formula, personalized on request.
3. Safety and compliance: responsible person, safety assessment, product information file, notification.
4. Packaging and branding: logo, label, mandatory information and product claims.
5. Small-batch production: trial batch, manufacturing to ISO 22716, filling.
6. Launch: sales channel, team, consultation and reorders.

Step 1: Idea, target group and the right route

You do not start with the active ingredient. You start with the person who will use your product. Three questions help you sharpen your focus:

• Who is it for? Regular clients at your studio, spa guests, the customers of your pharmacy or an online community – each group buys differently.
• How will you stand out? Through your advice, your brand or the product itself?
• How much of it should be yours? That decides which route fits.

At Novogenia, there are three routes. You can resell the personalized BeautyMe skincare – with no lab, no production and no startup costs. You can launch a proven base formulation as white label under your brand, the fastest route to your own brand. Or you can develop your own formula, which takes 3 to 5 months. The routes are compared side by side in White label, private label or your own formula?.

If you want to offer personalized cosmetics, settle the data question now: will the genetic information come from a new saliva sample, or do you already hold genotype data from your clients? Under the GDPR, genetic data belong to the specially protected categories of data – more in Genetic data and the GDPR. If you want to offer genetic analyses in Switzerland, check in advance who may order them there (Who may offer genetic tests?).

Step 2: Your own formula or a proven base

Novogenia makes three products: a day serum, a night serum and a body lotion. That is deliberately lean – three products that together form a skincare routine: morning, evening and for the body. Every route leads to one of these three formats.

With white label, you build on a proven base formulation that is filled under your brand. Formula and manufacturing are already established; you focus on brand, presentation and sales.

With your own formula, you bring the idea or your active-ingredient wishes, and we implement them correctly in terms of galenics and regulation. Galenics is the art of turning active ingredients into a product that stays stable and is pleasant to apply. It is like baking: the same ingredients can make a fluffy cake or a brick, depending on the recipe. Development takes 3 to 5 months.

Personalization works through genes. The result of the genetic analysis changes which ingredients go into the formula and at what dosage. The analysis reads genes on skincare topics such as collagen breakdown and production, the skin’s UV protection, hydration, oxidative stress, coenzyme Q10, selenium and inflammation tendency. The starting point is a saliva sample or genotype data a partner already holds. How this works in detail is explained in Personalized cosmetics.

Before you go into series production, you can get a small trial batch on request. It lets you check texture, scent and look in the place where the product will later be sold.

Step 3: Safety and compliance

Everything starts with the purpose. Under Art. 2 of the Cosmetics Regulation, a cosmetic product is meant to clean, perfume, change the appearance of, protect or keep in good condition the skin, hair or teeth, or to correct body odors. Healing or treating is not on that list. This framework shapes everything, from the formula to the label. Four obligations are at the center:

• Responsible person (Art. 4): a product may only be placed on the market if a responsible person established in the EU has been designated. Anyone who has a product made and markets it under their own name or trademark counts as the manufacturer in legal terms (Art. 2) and is initially responsible themselves. However, they can designate another person in the EU by written mandate, who accepts in writing. At Novogenia, we take on this role.
• Safety assessment (Art. 10): an expert with a university degree in a field such as pharmacy, toxicology or medicine assesses safety – taking into account the intended use and how much of each ingredient can enter the body. The result is recorded in the safety report, which is kept up to date.
• Product information file (Art. 11): among other things, it contains the product description, the safety report, the manufacturing method with a statement on good manufacturing practice and, where needed, proof of the claimed effect. It is kept for ten years after the last batch.
• Notification (Art. 13): before launch, the product is notified electronically to the European Commission through the Cosmetic Products Notification Portal (CPNP).

In Switzerland, the Ordinance of the Federal Department of Home Affairs on cosmetic products (VKos) applies. There, too, every cosmetic product needs a product information file with a safety report prepared by a qualified expert, and good manufacturing practice corresponds to ISO 22716 (FSVO). The EU notification via the CPNP concerns the EU market; if you supply Switzerland, the obligations of the VKos apply.

What the responsible person does in detail is described in Responsible person, safety assessment, notification.

Step 4: Packaging, label and product claims

Now your product gets its face: logo, label and packaging are created in your design. With white label, Novogenia does not appear as a brand – your clients see your brand.

Plan the mandatory information early, because space on a small bottle is tight. Under Art. 19 of the Cosmetics Regulation, the container and packaging must show, among other things:

• name and address of the responsible person
• nominal content by weight or volume
• date of minimum durability – or, for a durability of more than 30 months, the period after opening
• particular precautions for use
• batch number
• function of the product, unless it is clear from its presentation
• list of ingredients

Product claims matter just as much. A product must not imply characteristics it does not have (Art. 20). Regulation (EU) No 655/2013 sets six criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. Wording such as “cares for” or “supports skin hydration” fits a cosmetic product; “heals” or “treats” does not. The details are in Labeling cosmetics and Advertising cosmetics.

Step 5: Small-batch production

Novogenia produces cosmetics from small batches. You start small, get to know your clients and grow with them – from the first trial batch to large-scale production. How to plan quantities and timeline wisely is shown in Small batches, quantities and timeline.

Production runs on our own lines in Eugendorf, to ISO 22716, the standard for good manufacturing practice in cosmetics. Under Art. 8 of the Cosmetics Regulation, manufacturing in line with this harmonized standard is presumed to meet the requirements. Add tested raw materials and full traceability: the batch number links every bottle to its production run. For personalized skincare, the product is formulated and filled for the individual person after the analysis. More in Quality to ISO 22716.

Step 6: Launch and sales

How your product reaches your client depends on the sales channel. Two models have proven themselves:

• On site: the saliva sample is taken at the studio, spa or hotel – it only takes a few minutes. The sample goes to our lab, the analysis takes 4 days, and you hand over the finished, personalized products.
• Online: your clients order the analysis directly from your shop. Novogenia ships the sample kit, runs the analysis and delivers the products.

Spas and wellness hotels often offer the skincare as a takeaway or by subscription after the stay. For your team, there is the free NOVO Academy, including a course on the genetics of skin. Which channels suit you is described in Selling cosmetics: studio, spa, pharmacy, online.

Checklist: getting cosmetics manufactured

• Target group and positioning defined: who is the line for, and how does it stand out?
• Route chosen: resell BeautyMe, white label or your own formula.
• Format settled: day serum, night serum, body lotion – or all three.
• For personalization: data source, consent and data protection in place.
• Responsible person designated; safety assessment, product information file and notification completed before launch.
• Label designed with all mandatory information, with space planned for the ingredient list.
• Advertising copy checked: cosmetic purpose, no promises of cure, every claim backed by evidence.
• Trial batch checked: texture, scent and look suit your target group.
• Sales channel, team and training prepared for launch.

Frequently asked questions

Related: Contract manufacturer for personalized cosmetics · Quality assurance at Novogenia · How to get supplements manufactured

Note: 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.