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Challenges and Difficulties of Small-Scale Cosmetic Producers in Practice, Part 3

This third part of the series focuses on practical, real-world issues that repeatedly appear in small-scale cosmetic production - not as isolated mistakes, but as structural challenges resulting from limited access to regulatory knowledge, technical training, and industry-standard manufacturing practices.

AUTHOR: Gordana Gorinšek, MSc in Phytomedicine Senior Cosmetic Safety Assessor Expert Regulatory Affairs Consultant

Story 7: weight vs. volume – why “mL” is not acceptable in a formulation

In small-scale cosmetic manufacturing, many formulations are still written the way recipes are written: a mix of grams for solids and milliliters for liquids. It feels logical. It feels practical. And it feels “close enough”.

But in professional cosmetic formulation – and in regulatory documentation – this approach is a fundamental mistake. A cosmetic formula is not a kitchen recipe. It is a controlled, reproducible specification. And for that, the only reliable unit is mass.

The problem: volume depends on density

A milliliter is not a fixed amount of “ingredient”. It is a fixed amount of volume – the physical volume the material occupies in a laboratory container. Volume is defined as the amount of three-dimensional space occupied by a substance. Unlike mass, volume changes with density.

The actual amount of ingredient you add depends on density – and density is not constant across raw materials. There is only one commonly used ingredient where milliliters and grams can be considered equivalent under standard conditions: water. 1 mL of water is approximately equal to 1 g of water.

A few real-world examples:

  • 10 mL of decyl oleate does not weigh the same as 10 mL of almond oil,
  • 10 mL of olive oil does not weigh the same as 10 mL of castor oil.

Plant oils, in particular, vary by batch, origin, fatty acid profile, and temperature.

A formula written in mixed units creates a basic question with no defensible answer: What is the actual concentration in the finished product? The only way to be certain and confident is to weigh each and every ingredient and calculate concentration as mass fraction (% w/w). In cosmetic science, precision is not optional – it is the foundation of safety.

Story 8: drops are not a measurement – the hidden risk of dosing essential oils by drops

Why “a few drops” is not a cosmetic formulation parameter

In small-scale cosmetic production, essential oils are often still described using drops – “10 drops of lavender”, “5 drops of tea tree”, or similar instructions. This approach originates from aromatherapy and hobby formulation. However, once a product is placed on the cosmetic market, this method becomes technically unreliable.

A cosmetic formula must be measurable, reproducible, and auditable. A drop is none of these.

Why this matters: essential oils are complex active ingredients

Essential oils are not only fragrance components. They are complex mixtures of biologically active substances and may contain:

  • skin sensitizers,
  • phototoxic substances,
  • restricted constituents,
  • fragrance allergens with declaration thresholds.

Without precise measurement, it becomes impossible to:

  • verify compliance with fragrance standards,
  • calculate allergen declaration requirements,
  • perform reliable safety assessment exposure calculations.

If the exact amount is unknown, the risk cannot be properly assessed.

The professional solution: convert drops into weight and fix the formula in % w/w.

The transition is simple. During development:

  • determine the mass corresponding to a defined number of drops under controlled conditions by weighing the dispensed material.
  • convert this value into % w/w in the final formula.

During manufacturing:

  • weigh essential oils using calibrated scales.
  • record weighed amounts in batch documentation.

This ensures reproducibility, supports safety assessment, and protects both the manufacturer and the consumer. In cosmetic formulation, a drop may feel precise – but only weight can prove it.

Story 9: when cosmetics look like food – creativity vs. consumer safety

Why food-like cosmetics are more than a design choice

Small cosmetic brands often build their identity through creativity and sensory storytelling. However, one area where creativity can create real safety and legal risks is cosmetics that visually imitate food.

This is especially common in small-scale production of soaps shaped like cakes, cupcakes, desserts, chocolates, or fruits. While these products may be visually attractive and fun, they can create a foreseeable safety risk – especially for children.

Why this matters: risk of accidental ingestion

Products that look, smell, or are packaged like food may be confused with food. This creates a foreseeable ingestion risk. Children are particularly vulnerable because they rely on visual recognition, they associate sweet smells and colours with food, they cannot reliably distinguish product categories. If a cosmetic product can reasonably be mistaken for food, it creates a safety hazard regardless of the manufacturer’s intention.

The regulatory principle: preventing confusion, not creativity

Council Directive 87/357/EEC specifically addresses this issue and is reflected within the safety framework of Cosmetic Regulation (EC) No 1223/2009.

Products that:

  • are not food,
  • resemble food in appearance, smell, or packaging,
  • and may be confused with food by consumers

are considered unsafe because they may encourage accidental ingestion. The regulatory focus is not on limiting creativity, but on preventing predictable misuse.

Food-inspired naming or marketing concepts may be acceptable when clear cosmetic identity is maintained, but only if combined with standard cosmetic packaging, clear cosmetic labelling and no realistic edible appearance. The key factor is clear product identity.

If the product could realistically be mistaken for food by a child, it creates a safety and compliance risk. Separating storytelling from physical product design is often the safest strategy. In cosmetic design, creativity should attract attention – not create confusion. And true product creativity should always be intentional, informed, and safety-driven.


Aromatični kutak Ltd.

+ 385 98 1750 934

info@aromaticnikutak.hr

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