🇪🇺EU Compliance

Cosmetic Safety Assessment: Complete Process Guide

Step-by-step guide to cosmetic safety assessment in the EU — SCCS methodology, MoS calculation, exposure assessment, toxicological endpoints, and NAMs.

Verified January 17, 2026

Guide Information

Published by: Global Cosmetic Regs Editorial Team

Last updated: January 17, 2026

Verified against: SCCS Notes 12th, Annex I - PIF/CPSR

Sources: 11 official documents

View our methodology →

This guide is part of our comprehensive CPSR Cosmetics Guide: EU Safety Report Requirements 2026 resource.

What is Cosmetic Safety Assessment?

Cosmetic safety assessment is the systematic scientific evaluation of a cosmetic product to determine whether it is safe for human use under normal and reasonably foreseeable conditions. According to EU Regulation 1223/2009, every cosmetic product placed on the EU market must undergo a safety assessment performed by a qualified safety assessor.

Legal Requirement

The safety assessment requirement is absolute — no cosmetic product may be placed on the EU market without a documented safety assessment forming Part B of the Cosmetic Product Safety Report (CPSR). This requirement applies regardless of product complexity, price point, or business size.

The safety assessment process integrates multiple scientific disciplines:

  • Toxicology — Evaluating potential harmful effects of ingredients
  • Exposure science — Determining how much of a substance reaches the body
  • Risk assessment — Characterizing whether exposure levels present acceptable risk
  • Chemistry — Understanding ingredient interactions and stability

Article 10: Safety Assessment Requirements

Article 10 and Annex I of the Cosmetics Regulation establish the safety assessment framework:

Article 10 Key Requirements

  • Safety assessment must be performed before market placement
  • Assessment must be documented in the CPSR (Part B)
  • Only qualified safety assessors may sign the assessment
  • Assessment must cover finished product, not just ingredients
  • Must consider reasonably foreseeable use conditions
  • Must be updated when new safety-relevant information emerges

Annex I Structure

The CPSR has two parts with distinct purposes:

CPSR Part A vs Part B
ElementPart APart B
PurposeTechnical dossierSafety assessment
ContentProduct informationSafety conclusions
ResponsibilityCan be prepared by manufacturerMust be signed by safety assessor
IncludesFormula, specs, stability, micro, packagingToxicology review, exposure assessment, conclusions

Source: EU Regulation 1223/2009, Annex I

SCCS Notes of Guidance Overview

The SCCS Notes of Guidance (12th Revision, 2023) provides the methodological framework for cosmetic safety assessment. While technically guidance for SCCS opinions on specific ingredients, this document has become the de facto standard for all cosmetic safety assessments.

Key Principles from SCCS Notes

SCCS Safety Assessment Principles

  • Assessment must be evidence-based using available scientific data
  • Margin of Safety (MoS) approach is the primary risk characterization tool
  • Exposure assessment must reflect realistic use conditions
  • Read-across and in silico methods acceptable where appropriate
  • Animal testing data cannot be generated but historical data may be used
  • New Approach Methodologies (NAMs) increasingly important

The Safety Assessment Process

Step 1: Hazard Identification

Hazard identification determines what adverse effects each ingredient could potentially cause. This involves reviewing:

Data Sources for Hazard Identification
Data TypeSourceReliability
Published toxicology studiesScientific literature, TOXNETVaries by study quality
SCCS opinionsSCCS databaseHigh — peer-reviewed
CIR (Cosmetic Ingredient Review)CIR publicationsHigh — expert panel reviewed (US-based; SCCS is EU equivalent)
REACH registration dossiersECHA databaseMedium-High
Supplier safety dataTDS, SDS, certificatesVaries by supplier
In silico predictionsQSAR modelsSupporting evidence only

Source: SCCS Notes of Guidance

Data Quality Matters

The safety assessor must critically evaluate all data sources. Poorly conducted studies, studies on different exposure routes, or data from structurally dissimilar substances require careful consideration before use in safety assessment.

Step 2: Dose-Response Assessment

Dose-response assessment determines the relationship between exposure level and adverse effect severity. Key outputs include:

Key Toxicological Endpoints
EndpointDefinitionTypical Test
NOAELNo Observed Adverse Effect Level90-day oral toxicity study
LOAELLowest Observed Adverse Effect LevelDerived when NOAEL unavailable
BMDBenchmark DoseStatistical modeling of dose-response
PODPoint of DepartureStarting point for MoS calculation

Source: SCCS Notes of Guidance

BMD Now Preferred

The SCCS now recommends the Benchmark Dose (BMD) approach over traditional NOAEL determination when sufficient dose-response data is available. BMD provides a more statistically robust Point of Departure by modeling the full dose-response curve rather than relying on specific study dose groups.

Step 3: Exposure Assessment (SED Calculation)

Exposure assessment quantifies how much of each ingredient reaches systemic circulation. The SCCS provides standardized exposure scenarios:

SCCS Default Exposure Parameters
Product TypeAmount Applied (g/day)Retention FactorSurface Area (cm²)
Body lotion7.821.0 (leave-on)15670
Face cream1.541.0 (leave-on)565
Hand cream2.161.0 (leave-on)860
Lipstick0.0571.0 (ingested)N/A
Shampoo10.460.01 (rinse-off)1440
Shower gel5.000.01 (rinse-off)17500

Source: SCCS Notes of Guidance, Appendix 4

Systemic Exposure Dose (SED) Calculation

The SED formula standardizes exposure to a per-kilogram body weight basis:

SED Calculation Formula

SED (mg/kg bw/day) = (C × DA × DAp × A) / (BW × 1000) Where: - C = Concentration in product (%) - DA = Amount applied daily (g/day) - DAp = Dermal absorption (fraction) - A = Number of applications per day - BW = Body weight (default 60 kg)

Step 4: Risk Characterization (Margin of Safety)

The Margin of Safety (MoS) is the primary metric for determining whether an ingredient is safe at its intended concentration:

MoS Calculation

MoS = POD / SED Where: - POD = Point of Departure (usually NOAEL from systemic toxicity study) - SED = Systemic Exposure Dose Acceptable MoS ≥ 100

The 100-fold safety factor accounts for:

MoS Safety Factors
FactorMagnitudeAccounts For
Interspecies10×Differences between test animals and humans
Intraspecies10×Variation within human population
Combined100×Standard default safety margin

Source: SCCS Notes of Guidance

Toxicological Endpoints Required

A comprehensive safety assessment addresses multiple toxicological endpoints:

Required Toxicological Endpoints
EndpointPurposePriority
Acute toxicitySingle-dose effectsFor all ingredients
Irritation/corrosivityLocal skin/eye effectsEssential for leave-on
Skin sensitizationAllergic potentialEssential for all products
Dermal absorptionSystemic exposureCritical for MoS
Repeated dose toxicityChronic effects, NOAELRequired for MoS
Mutagenicity/genotoxicityDNA damage potentialRequired (no threshold)
CarcinogenicityCancer potentialWhen triggered by alerts
Reproductive toxicityFertility, developmentalWhen triggered
ToxicokineticsADME profileSupporting information
PhototoxicityLight-induced effectsFor UV-absorbing ingredients

Source: SCCS Notes of Guidance

New Approach Methodologies (NAMs)

Since the EU animal testing ban (Article 18) prohibits generating new animal test data for cosmetic purposes, safety assessments increasingly rely on NAMs.

Animal Testing Ban Timeline

2004: Ban on testing finished cosmetic products on animals 2009: Ban on testing cosmetic ingredients on animals 2013: Full marketing ban on products containing ingredients tested on animals (including data from outside EU)

Types of NAMs

New Approach Methodologies
NAM TypeExamplesApplication
In vitro assaysEpiSkin, SkinEthic, h-CLATIrritation, sensitization screening
In silico methodsQSAR, read-across, TTCHazard prediction, data gap filling
Biokinetic modelsPBPK modelingDermal absorption, systemic exposure
Omics approachesToxicogenomics, metabolomicsMechanism-based assessment
Integrated approachesIATA, AOPWeight-of-evidence conclusions

Source: SCCS Notes of Guidance

Read-Across

Read-across uses data from structurally similar substances to fill data gaps. Valid read-across requires documented justification for structural similarity, mechanistic relevance, and comparable exposure scenarios.

Next Generation Risk Assessment (NGRA)

NGRA represents the evolution of cosmetic safety assessment, integrating NAMs into a cohesive framework:

NGRA Framework Steps

1
Exposure-Led Assessment

Start by defining realistic exposure scenarios for the specific product and use pattern.

2
Hypothesis-Driven Testing

Use existing knowledge to identify relevant hazards before generating new data.

3
Tiered Approach

Begin with simpler methods, progressing to more complex only if needed.

4
Bioactivity Comparison

Compare internal exposure concentrations to bioactivity thresholds.

5
Integrated Evidence

Combine multiple data streams using weight-of-evidence approach.

Special Considerations

Products for Children

Regulation 1223/2009 requires enhanced safety assessment for products intended for children under 3 years:

Additional Requirements for Children's Products

  • Higher exposure estimates due to lower body weight
  • Consider differences in skin permeability
  • Account for mouthing behavior (toys, teethers)
  • Restrict certain ingredients (e.g., certain preservatives)
  • More conservative MoS may be appropriate

CMR Substances

Article 15 prohibits CMR substances, but Category 2 substances may be used if SCCS concludes they are safe:

  • SCCS opinion must specifically address cosmetic use
  • Assessment must demonstrate safe exposure levels
  • Typically requires additional controls or concentration limits

Nanomaterials

SCCS Guidance on Nanomaterials requires:

  • Physical-chemical characterization specific to nano form
  • Assessment of nano-specific toxicity concerns
  • Consideration of altered dermal penetration
  • Specific CPNP notification requirements

Key Takeaways

Safety assessment is a legal requirement for every EU cosmetic product — no exceptions
The SCCS Notes of Guidance provides the scientific framework for assessment
Margin of Safety ≥ 100 is the primary safety threshold based on NOAEL/SED ratio
Exposure assessment must use realistic parameters for the specific product type
NAMs are increasingly important due to animal testing ban
Special considerations apply for children's products, CMR substances, and nanomaterials
Safety assessors must have specific qualifications under Article 10(2)
CPSRs must be updated when new safety-relevant information emerges

Frequently Asked Questions

Under Article 10(2) of Regulation 1223/2009, safety assessors must hold a diploma or formal qualification in pharmacy, toxicology, medicine, or a similar discipline recognized by an EU Member State. 'Similar disciplines' typically include chemistry, biochemistry, dermatology, and related life sciences. The assessor must have adequate theoretical and practical knowledge.

The Margin of Safety (MoS) is the ratio of the Point of Departure (usually NOAEL from toxicity studies) to the Systemic Exposure Dose (SED). The 100-fold threshold accounts for two 10× safety factors: interspecies extrapolation (animal to human) and intraspecies variation (individual human differences). MoS ≥ 100 indicates acceptable safety.

Existing animal test data (generated before the ban) can be used. Data from non-cosmetic purposes (e.g., pharmaceutical, REACH) can also be used. However, you cannot commission new animal testing specifically for cosmetic safety assessment. NAMs must be used for any new data generation.

Dermal absorption is the fraction of an applied substance that penetrates through skin into systemic circulation. It's critical for MoS calculation because systemic exposure (SED) depends on how much ingredient actually enters the body. Default absorption values or specific study data can be used.

The CPSR must be updated whenever new safety-relevant information becomes available — this includes new toxicological data, changes in ingredient restrictions, formulation changes, or reports of adverse effects. There's no fixed timeline, but annual review is good practice.

Threshold of Toxicological Concern (TTC) is a screening tool for substances with limited data. If exposure is below TTC thresholds (typically 1.5 µg/kg bw/day for non-genotoxic substances), the substance is considered of low concern. TTC cannot be used for substances with known high-potency endpoints or certain structural alerts.

Yes. 'Natural' does not mean safe. Natural ingredients require the same rigorous assessment as synthetic ones. Complex natural mixtures (essential oils, plant extracts) present additional challenges requiring assessment of major components and potential for allergens, irritants, or toxic constituents.

An Adverse Outcome Pathway (AOP) describes the mechanistic sequence from molecular initiating event to adverse health outcome. AOPs help design testing strategies, interpret NAM data, and support weight-of-evidence conclusions. They're particularly useful for endpoints like skin sensitization where validated AOPs exist.

Sources & References
  1. European Union. "Regulation (EC) No 1223/2009 on cosmetic products (consolidated)." (2009-11). eur-lex.europa.eu. Accessed 2026-01-12.
  2. European Union. "Regulation (EC) No 1223/2009 Annex I - Product Information File (PIF/CPSR)." (2009-11). eur-lex.europa.eu. Accessed 2026-01-12.
  3. European Commission. "SCCS Notes of Guidance - 12th Revision (2023)." (2023-05). health.ec.europa.eu. Accessed 2026-01-12.
  4. European Commission. "SCCS Notes of Guidance - 11th Revision (2021)." (2021-03). health.ec.europa.eu. Accessed 2026-01-12.
  5. European Commission. "SCCS Opinions Database." (2009-01). health.ec.europa.eu. Accessed 2026-01-12.

January 17, 2026

Comprehensive guide created covering EU cosmetic safety assessment process

January 17, 2026

Initial publication