Specialised Products

Baby & Children's

Products for babies and young children are held to the most cautious assessment in cosmetics. Age-specific exposure and the margin of safety, the ingredient restrictions and warnings, stricter microbiology, and the limits on gentleness and hypoallergenic claims.

Products for babies and young children are held to the most cautious assessment in all of cosmetics. A child is not a small adult: the skin is thinner and more permeable, the ratio of body surface area to weight is higher, and behaviour, hand-to-mouth contact, time in a nappy, means exposure has to be modelled differently. The assessment reflects all of that rather than scaling down an adult product.

Age-specific exposure and the margin of safety

The SCCS Notes of Guidance sets out exposure factors specific to children by age, the body weights, surface areas and product quantities that apply to infants and young children rather than adults. The safety report uses these, and a higher margin of safety is expected, because the same systemic exposure represents a larger dose relative to a child’s body weight. For products intended for children under three, Annex I requires a specific assessment of their suitability, and that specific reasoning has to be in the file.

Restricted ingredients and warnings

A number of ingredients carry child-specific limits, prohibitions or warnings. Triclosan and triclocarban carry restrictions and warnings against use for young children; fluoride toothpastes require the child-supervision guidance; phenoxyethanol has been scrutinised for use in the nappy area; and ingredients such as camphor, menthol and certain essential oils are treated with caution for young children because of their physiological effects. The fragrance-allergen load is kept to a minimum, and the assessor weighs every ingredient against a child’s lower tolerance rather than an adult’s.

Microbiology and formulation

Children’s products are held to stricter microbiological standards and formulated for low irritation potential. A “no tears” or low-sting performance is a formulation quality, not a substitute for the safety assessment, and the preservative system still has to be both compliant and proven effective by challenge testing, which is harder to achieve in the mild formulations the category demands.

Claims

Claims are tightly constrained. “Hypoallergenic” may only be used where the allergenic potential has genuinely been minimised and can be evidenced, under the Commission’s Technical Document, and gentleness or suitability-for-babies claims must be substantiated and must not stray into implying a medicinal benefit such as treating eczema or cradle cap.

How we help

We assess baby and children’s products to the child-specific exposure factors and the higher margin of safety the category requires, provide the specific under-three assessment, keep restricted ingredients and warnings correct, design and challenge-test a preservative system that works in a mild formulation, and hold gentleness and hypoallergenic claims to the evidence the guidance demands.

Relevant services

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CPSR

From £70 · 2 to 3 days

The Cosmetic Product Safety Report is the safety assessment required under Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product may be placed on the UK or EU market. Prepared and signed by a qualified safety assessor.

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Testing

From £75

Stability, microbiology, photoprotection and analytical testing carried out in our three in-house laboratories. Analytical work is not contracted out; results pass directly to the assessor preparing your CPSR.

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Labelling

From £195 · from receipt of artwork

Independent review of packaging artwork against Article 19, and of product claims against the six Common Criteria of Regulation (EU) 655/2013. Label review £195; per-claim review from £125; substantiation dossiers from £1,495.

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Frequently asked questions

How is the safety of a baby or children's cosmetic assessed?

In the EU and UK, to child-specific exposure factors in the SCCS Notes of Guidance, using a child's body weight, surface area and use patterns rather than an adult's, with a higher margin of safety expected. Products for children under three require a specific assessment of suitability under Annex I.

Which ingredients are restricted in children's cosmetics?

In the EU and UK, several ingredients carry child-specific limits or warnings, including triclosan and triclocarban (warnings against use for young children), fluoride (child-supervision guidance), and ingredients such as camphor, menthol and certain essential oils treated with caution. Fragrance-allergen content is minimised and hypoallergenic claims must be evidenced.

What is a CPSR?

A Cosmetic Product Safety Report (CPSR) is the safety assessment required by Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product is placed on the UK or EU market. Annex I sets out two parts: Part A, the cosmetic product safety information (composition, physico-chemical and microbiological characteristics, stability, exposure and the toxicological profile of each substance), and Part B, the safety assessment, in which a qualified assessor states and reasons the conclusion on safety. It is the pivotal scientific document held within the Product Information File.

What is a Preservative Efficacy Test (challenge test)?

A Preservative Efficacy Test, also called a challenge test, demonstrates that a product's preservative system controls microbial growth across its life. Oxford Biosciences performs it to ISO 11930 for £165: the product is inoculated with the five specified challenge organisms (Staphylococcus aureus, Escherichia coli, Pseudomonas aeruginosa, Candida albicans and Aspergillus brasiliensis), and viable counts are enumerated over a 28-day window against the Criterion A or B log-reduction thresholds. Typical turnaround is six weeks, reflecting the protocol duration plus enumeration and reporting.

What are the rules on preservatives like MIT and parabens?

In the EU and UK, preservatives may only be used if listed in Annex V, within its limits. Methylisothiazolinone is prohibited in leave-on products and limited to 0.0015% in rinse-off; several parabens are banned and the rest capped; phenoxyethanol is limited to 1%. The system must also be proven effective by challenge testing.

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