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- Cosmetic toxicologist at Euverify, specialising in cosmetic product safety, PIF and CPSR preparation, and regulatory compliance with EU and UK Cosmetic Regulations. Conducts toxicological assessments of cosmetic ingredients and formulations, reviews product safety reports and manages CPNP and SCPN product notifications. Dedicated to supporting brands in achieving compliance with EU and UK cosmetic standards.
Nanomaterials in Cosmetics: How to Audit and Label Ingredients Under the New EU Rules
Tiny particles can have enormous regulatory implications.
Nanomaterials have been used in cosmetics for years to enhance texture, absorption, and protection. But as science advances, so do the regulations that govern these materials. The European Union’s updated framework, introduced through Regulation (EU) 2024/858, amends the long-standing Cosmetics Regulation (EC) 1223/2009 to clarify how nanomaterials are defined, notified, and labelled.
For cosmetic brands, these updates mean it’s no longer enough to assume compliance. Ingredient data, product safety documentation, and labels all need to align with the new definitions and technical requirements.
This guide walks you through how to audit your formulations, label nanomaterials correctly, and keep your Product Information File (PIF) and Cosmetic Product Safety Report (CPSR) ready for inspection under the new EU rules.
The Evolving Regulatory Context
The EU Cosmetics Regulation (EC) 1223/2009 has always required brands to assess ingredient safety and ensure transparency when using materials in nano form. With the adoption of Regulation (EU) 2024/858, these requirements have been strengthened and clarified.
The updated framework introduces several key changes:
- Updated definition of nanomaterial: The term now explicitly covers insoluble or biopersistent substances with one or more external dimensions between 1 nm and 100 nm. This includes aggregates and agglomerates that still show nanoscale characteristics.
Example of nanoscale range (1–100 nm) under EU definition — comparing nano and non-nano particles.
- Earlier notification: Any new nanomaterial intended for use in cosmetics must now be notified to the Cosmetic Products Notification Portal (CPNP) at least six months before being placed on the EU market.
- Reinforced safety evaluation: Each notification must include complete safety data, particle size characterisation, and a toxicological profile. If safety cannot be demonstrated, the European Commission refers the ingredient to the Scientific Committee on Consumer Safety (SCCS) for review.
Improved traceability and transparency: The public Catalogue of Nanomaterials in Cosmetics is updated regularly to list all notified nano ingredients and their intended uses.
Together, these measures are designed to make sure nanomaterials are both safe for consumers and properly identified at every stage of a cosmetic product’s lifecycle.
Why Size Matters in Cosmetics
Nanoparticles don’t always behave like their larger counterparts. At the nanoscale (1–100 nm), materials can develop new optical, chemical, or physical properties, such as greater transparency in sunscreens, increased surface activity, or different interactions with the skin.
This is exactly why the EU regulates nanoscale ingredients separately under Regulation (EU) 2024/858.
If a material stays insoluble and biopersistent at the nanoscale in the finished product, it must be labelled with “(nano)” and notified in the CPNP. However, if it dissolves, aggregates, or loses its nanoscale properties during formulation, it may no longer fall under the “nano” definition, which changes the compliance requirements.
Why Many Cosmetic Brands Still Struggle Complying with Nanomaterials
Even established cosmetic brands continue to face challenges when it comes to complying with nanomaterial requirements:
- Hidden nano ingredients: Some pigments, such as titanium dioxide, zinc oxide, carbon black, and silica, can exist in both conventional and nano forms. This makes supplier transparency absolutely essential.
- Incomplete supplier data: Particle size information is often missing, inconsistent, or based on outdated testing methods.
- “Nano by accident”: Certain manufacturing processes, like milling, coating, or emulsification, can unintentionally create nanoscale materials.
- Documentation gaps: Product Information Files (PIFs) and Cosmetic Product Safety Reports (CPSRs) often lack nano-specific exposure or toxicology data, which is one of the most common causes of non-compliance.
These issues make regular ingredient audits crucial. They help ensure compliance, maintain consumer safety, and prevent costly recalls or unwanted appearances in the EU’s public nanomaterial database.
How to Audit Your Ingredients for Nanomaterials
Step 1 – Identify potential nanomaterials
Start by reviewing your ingredient list for substances that are often manufactured in nano form, such as titanium dioxide, zinc oxide, silica, iron oxides, mica, carbon black, and UV filters.
Check the EU Catalogue of Nanomaterials and SCCS opinions to confirm whether any of your ingredients are officially recognized as nano.Step 2 – Request technical data from suppliers
Ask your suppliers to provide:- Particle-size distribution (using electron microscopy or dynamic light scattering)
- Surface-area data (BET method)
- Solubility and coating details
- A toxicological dossier or SCCS reference
Make sure this information reflects the ingredient’s final form in your formulation, not just the raw material.
Step 3 – Update your PIF and CPSR
In your Product Information File (PIF):- Part A should include a full description of the nanomaterial, its physicochemical properties, and exposure conditions.
- Part B (the CPSR) must contain the toxicologist’s assessment of nano-specific endpoints such as skin penetration, inhalation, and long-term accumulation.
All of this information should be traceable back to supplier certificates or SCCS safety assessments.
Step 4 – Verify your CPNP notification
When submitting your product in the Cosmetic Products Notification Portal (CPNP), select the “contains nanomaterials” option and upload the full documentation.
Each nano ingredient must be listed using its INCI name followed by “(nano),” exactly as it appears on your product label and in your PIF.- Particle-size distribution (using electron microscopy or dynamic light scattering)
Labelling Rules: When to Use “(nano)”
Under Article 19 of the EU Cosmetics Regulation, any ingredient used in nano form must be clearly indicated on the product label by adding “(nano)” immediately after its INCI name.
Example of correct labelling:
Titanium Dioxide (nano), Zinc Oxide (nano), Silica (nano)Common mistakes to avoid:
- Leaving out “(nano)” because the supplier did not provide particle-size information.
- Labelling ingredients as nano when they actually dissolve or aggregate in the final formulation, meaning they no longer have nanoscale properties.
- Using inconsistent ingredient names across the label, PIF, and CPNP entry.
The example below shows how nanomaterial ingredients should appear on a cosmetic product label under EU rules — and how common mistakes can make a product non-compliant.
- Leaving out “(nano)” because the supplier did not provide particle-size information.
REFERENCE: Regulation (EC) No 1223/2009, Article 19(1)(g) — “All ingredients present in the form of nanomaterials shall be clearly indicated in the list of ingredients. The names of such ingredients shall be followed by the word ‘nano’ in brackets.”
The use of lowercase “(nano)” isn’t just a style choice. It’s a regulatory requirement that ensures consistency across the EU and in multilingual INCI databases. Auditors have flagged labels using “(Nano)” or other variations as non-compliant, especially when compared to entries in the Cosmetic Products Notification Portal (CPNP), which also uses lowercase. To stay compliant, always write “(nano)” in lowercase immediately after the INCI name, exactly as it appears in the Regulation and your CPNP submission.
This detail goes beyond formatting. Always verify how the material exists in your finished product and keep evidence to support it in your technical documentation. The Responsible Person should confirm this consistency before the product is placed on the EU market.
Strengthening Safety and Consumer Transparency in Nanomaterial Regulation
Beyond compliance, nanomaterial regulation is also about consumer trust. The European Commission’s public Nanomaterials Catalogue lists every notified nano ingredient, the product categories it’s used in, and any related SCCS opinions.
This level of transparency helps consumers make informed choices and reduces confusion or misinformation about nanotechnology. Brands that can clearly demonstrate the safe, responsible use of nanomaterials often see their credibility grow. In today’s beauty market, openness about science and safety is becoming just as important as sustainability.
Preparing for Inspections and Market Surveillance of Nanomaterial Compliance
Market-surveillance authorities across EU Member States are now actively checking nanomaterial compliance. Expect cross-verification between CPNP notification data, product labels, and information contained in your PIF and CPSR.
To prepare:
- Keep complete test reports and safety evaluations readily available.
- Ensure supplier certificates are traceable to batch numbers.
- Update documentation whenever formulations, coatings, or raw-material suppliers change.
- Monitor new SCCS opinions — ingredients already approved may later require updated safety assessments if new evidence arises.
Failure to maintain accurate nano documentation can result in enforcement action, product withdrawal, or public disclosure of non-compliance.
The Audit Advantage: Turning Compliance into Leadership
Market surveillance authorities across EU Member States are now actively reviewing nanomaterial compliance. They’re cross-checking data from CPNP notifications against product labels and the information in your PIF and CPSR, so consistency across all three is essential.
Euverify Insight: Simplifying Nanomaterial Compliance
At Euverify, we help cosmetic brands transform complex nanomaterial obligations into structured, verifiable documentation. Our experts:
- Audit ingredient portfolios to identify potential nanomaterials
- Review supplier data and request missing particle-size or safety information
- Prepare nano-specific PIF and CPSR sections in line with EU Regulation 2024/858
- Ensure consistent labelling and CPNP notifications
- Coordinate with toxicologists and accredited labs for safety evaluations
If your formulations may contain nanomaterials, even unintentionally, we can help you confirm and document them correctly. This ensures your brand stays fully compliant and inspection-ready.
Final Takeaway
The EU’s renewed focus on nanomaterials marks a clear shift from simple ingredient disclosure to evidence-based safety and transparency.
For cosmetic manufacturers, the message is straightforward: know your ingredients, verify your data, and keep your documentation complete.
Brands that act early by auditing formulations, updating labels, and strengthening their PIFs will not only stay compliant but also lead the way in a new era of traceable, science-driven beauty.
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