Cosmetics and perfume

Sheni Labs · Cosmetics & perfume

Cosmetics and perfume

Creams, serums, shampoos, sunscreens, make-up and fragrance. The questions are the same as for a supplement — what is inside, is it disclosed, is it safe, does it do what it says — but the rules are different, and the ingredient list (INCI) is the key.

What we check

  1. The INCI list. Every ingredient by its International Nomenclature of Cosmetic Ingredients name, in descending order of concentration; an incomplete or missing list is a “not assessable”.
  2. Restricted and prohibited substances. Against the annexes of the EU Cosmetics Regulation (EC) No 1223/2009 — prohibited substances (Annex II), restricted substances and their limits (Annex III), permitted colourants, preservatives and UV filters (Annexes IV–VI).
  3. Fragrance allergens. Allergens that must be named on the label above threshold — the list was extended from 26 to more than 80 substances by Regulation (EU) 2023/1545, with transition periods to 2026–2028.
  4. Substances of concern. Classified CMR substances, endocrine disruptors under assessment by the Scientific Committee on Consumer Safety, and intentionally added microplastics restricted under Regulation (EU) 2023/2055 (rinse-off microbeads banned since October 2023, other categories phased).
  5. Claims. Cosmetic claims must meet the common criteria of Regulation (EU) No 655/2013 — legal, truthful, evidenced, honest, fair, informed; “clinically proven” needs a study, “hypoallergenic” needs testing, “free from” claims are restricted.
  6. Safety and documentation. For products placed in the EU: a Product Information File, a safety assessment by a qualified assessor, notification in the Cosmetic Products Notification Portal and a responsible person; for Georgia, the applicable technical regulation and import documentation.
  7. Sunscreens and children’s products. SPF and UVA claims against the test methods; stricter judgement for products intended for children under three.

Perfume in particular

  • Fragrance formulas are protected and listed as “parfum”, but allergens above threshold must still be named — a perfume that lists none at a meaningful concentration is a flag.
  • Alcohol-based perfume has a different exposure profile from a leave-on cream; the lab evaluates by product type.
  • “Natural” is not a safety claim: essential oils carry many of the named allergens.

Verdicts

RecommendedEvidence supports the use; ingredients, dose and form are right; labelling is complete; no safety signal.
Acceptable with caveatsUsable, but with a stated limitation: weak evidence for a claim, a non-optimal form, an avoidable additive, or a price out of line with equivalents.
Not recommendedA safety concern, an undisclosed or misleading ingredient, an illegal claim, a dose that is ineffective or excessive, or no verifiable documentation.
Not assessableDocumentation insufficient to reach a verdict; we say what is missing.
Automatic “Not recommended”A product fails if any of its ingredients is prohibited for that use in any of the reference jurisdictions — Georgia, any EU member state, the United Kingdom, the United States, Canada, Australia or Japan — regardless of whether it is lawful where the product is sold. The reasoning is public-health reasoning: a prohibition by one competent regulator is evidence of a safety concern that does not stop at a border, and online sales do not stop at borders either. The verdict names the jurisdiction, the legal basis and the date. A dose limit or restriction elsewhere (as opposed to a prohibition) does not trigger the rule: it leads to “Acceptable with caveats” with the limit stated, or “Not recommended” if the product exceeds it by a wide margin.

Where the evidence comes from

A cosmetic ingredient module (INCI encyclopaedia and product checker) is in development on supplement.ge; until it is live, verdicts on cosmetics are issued on request. Get a verdict →