How to Start a Skincare Brand: A Practical Guide for Founders

Start a private label skincare line or develop your own formula?

The fastest way for most founders to start is a private label skincare line. You choose from a manufacturer’s existing, tested formulas and adapt them to your brand with packaging, fragrance and, where possible, adjustments to actives or texture. You avoid funding a full development project and can move to samples quickly. Rowe Cosmetics offers this route through private label manufacturing, with formulas such as a glycolic and salicylic acid peeling serum, a niacinamide and zinc PCA anti-acne cream, a ceramide and hyaluronic acid moisturiser, an aloe vera and panthenol cleansing gel and an SPF sunscreen with ceramide NP.

If your brand is built on a unique recipe, custom development is the better choice. Our in-house R&D laboratory can develop a new formula with you or produce your existing one through contract manufacturing. R&D support is free of charge for our customers. For a detailed comparison, see OEM vs ODM cosmetics.

Budget areas to plan for

Every project is different, but founders should plan budget for these areas:

• Product development and samples
• Packaging components and printing
• First production order, whose size depends on the manufacturer’s MOQ for your product and packaging
• Safety assessment, Responsible Person and notification or listing costs in each market
• Branding, photography, website and marketing
• Shipping, duties and warehousing

Marketing and regulatory costs are often underestimated compared with production. Ask your manufacturer for a quote early so you can plan the rest around real figures.

Cosmetic regulations in the EU, UK and USA: an overview

The following is a high-level summary for planning purposes only. Rules change, and details depend on your products and business set-up, so always confirm requirements with a qualified regulatory consultant or your Responsible Person.

European Union

Cosmetic products placed on the EU market must comply with Regulation (EC) No 1223/2009. Key points for a new brand:

• Each product needs a Responsible Person established in the EU, who ensures compliance. The brand owner must appoint this person or company; the manufacturer outside the EU cannot fill the role by default.
• A Product Information File (PIF) including a Cosmetic Product Safety Report prepared by a qualified safety assessor must be available.
• Products must be notified through the CPNP (Cosmetic Products Notification Portal) before being placed on the market.
• Labels must meet EU requirements, including the INCI ingredient list, and claims must be supported by evidence.

United Kingdom

Great Britain has its own cosmetics regime following Brexit, closely based on the EU framework:

• A UK Responsible Person based in the UK is required, again appointed by the brand owner.
• Products must be notified through the SCPN (Submit Cosmetic Product Notification) service before sale.
• A product safety report and product information file are required, as in the EU.
• Northern Ireland follows EU rules, so products sold there are notified via the CPNP.

United States

In the USA, cosmetics are regulated by the FDA, and the Modernization of Cosmetics Regulation Act (MoCRA) introduced new obligations:

• Facility registration: facilities that manufacture or process cosmetics for the US market are subject to FDA registration requirements.
• Product listing: the responsible person, typically the brand owner whose name appears on the label, lists each product with the FDA.
• The responsible person must also maintain safety substantiation, handle serious adverse event reporting and meet labelling requirements.
• Sunscreens are regulated as over-the-counter drugs in the USA, not as cosmetics, and follow different rules. Discuss this early if your range includes SPF products.

How your manufacturer supports compliance

Regulatory responsibility sits with the brand owner and the appointed Responsible Person, but the manufacturer provides much of the technical input. At Rowe Cosmetics we:

• Develop formulas in line with EU Cosmetics Regulation (EC) No 1223/2009, and follow IFRA guidelines for fragrance.
• Provide formula and INCI information to support your safety assessment, notification and product listing.
• Produce under ISO 22716 (Cosmetics GMP) and ISO 9001 at our Istanbul facility.
• Verify SPF values of sunscreen products by laboratory SPF test.

We do not have an EU or UK office and do not act as Responsible Person, so you will need to appoint one for each market you enter.

Common mistakes new skincare brands make

• Printing packaging before the formula, INCI list and claims are final.
• Using claims such as “organic”, “clinically proven” or “dermatologically tested” without the certification or test data to back them.
• Launching too many products at once and tying up cash in slow-moving stock.
• Leaving the Responsible Person and notification steps until the goods are ready to ship.
• Choosing a manufacturer on price alone without checking certifications, communication and capacity to scale.