“Marketing is delaying the launch again!”
“The safety assessor just blocked another great idea!”
Sounds familiar?
In many cosmetic companies, tension between marketing, R&D, and regulatory affairs is a regular occurrence. Marketing aims to react swiftly to trends, creating distinct products and compelling communication that captures consumer attention. Meanwhile, the safety assessor must guarantee product safety, regulatory compliance, and the absolute verifiability of marketing claims.
Although the goals of both sides may seem inherently different, they are actually identical: to create a product that achieves commercial success while remaining completely safe for the consumer. The real problem arises when the safety assessor is brought into the loop only at the very end of the project lifecycle.
“It’s just a minor change” – The beginning of major complications
In practice, many costly delays and complications stem from seemingly insignificant decisions. For instance, marketing might propose that a mask originally developed as a rinse-off product should also be positioned as an overnight leave-on treatment. From a consumer perspective, this looks like an appealing added benefit.
However, from a safety assessment standpoint, this represents an entirely new exposure scenario. A leave-on product remains on the skin for hours. Consequently, this simple adjustment may require a complete re-analysis of regulated ingredient thresholds, a reassessment of allergen levels, extensive verification of raw material documentation, and in some cases, additional laboratory testing or a complete reformulation of the product. Changing just one sentence in the directions for use can pivot the entire launch timeline.
We don’t just purchase raw materials
Another frequent bottleneck involves new, innovative active ingredients. An exotic plant extract, a fascinating origin story, and high marketing potential can easily feel like the ultimate recipe for a bestseller.
Yet, a cosmetic product is only as safe as its individual components. Therefore, when sourcing a raw material, the technical documentation verifying its safety profile is just as critical as its physical properties. Specifications, raw material dossiers, toxicological data, impurity profiles, and manufacturing processes are all non-negotiable requirements for a rigorous safety assessment. Even the most highly marketable ingredient can bring a project to a sudden halt if it lacks the proper documentation.
Claims are not just a creative exercise
Marketing claims serve as one of the most vital communication channels for any cosmetic product. They are the vehicle through which a manufacturer informs consumers about a product’s unique properties, efficacy, or benefits.
The catch is that every single claim must be fully verifiable. Within the European Union, this is strictly governed by Regulation (EC) No 1223/2009 on cosmetic products and Commission Regulation (EU) No 655/2013, which establishes common criteria for the justification of claims used in relation to cosmetic products. Under these regulations, claims must be legally compliant, truthful, backed by adequate evidence, honest, and completely clear to the consumer. As a result, the question should never just be: “How do we want to market this product?” The far more critical question is: “What concrete evidence do we have to substantiate this claim?”
When communication shifts product classification
Particular caution is required for claims that inadvertently hint at a therapeutic or curative effect. A classic example is the claim “treats acne.” While it may sound specific and compelling from a marketing angle, acne is a certified medical condition.
Using this kind of language can cause regulatory authorities to contest the classification of the cosmetic product, raising the question of whether it has crossed the line into a medicinal product. The fallout from such a reclassification can be severe, including forced changes to branding, marketing materials, and labels, or even direct intervention and penalties from market surveillance authorities.
The earlier, the cheaper and safer
An ambitious marketing vision is never the issue. The real mistake is keeping the safety assessor in the dark until the formulation is finalized, the packaging is printed, and the launch date is set in stone.
Organizing a collaborative briefing with marketing, R&D, regulatory, and the safety assessor at the absolute beginning of a project changes everything. It allows the team to cross-verify raw material documentation early on, map out the necessary clinical or consumer tests to back up claims, evaluate the proposed application methods, and analyze potential compliance risks related to packaging and branding. This proactive alignment doesn’t just secure product safety; it safeguards your timeline, budget, and corporate resources.
A single, shared objective
Marketing gives the product its voice. The safety assessor defines the safe parameters for that voice. Neither function outranks the other.
The most successful cosmetic products are born at the intersection of creative vision and scientific rigor — where innovation is nurtured within the boundaries of safety and compliance from day one. A safety assessor doesn’t stop innovation. They ensure it reaches the market safely.
