Faq | Notification And Labeling Requirements For Nano-Containing Cosmetic Products

FAQ | Notification and Labeling Requirements for Nano-Containing Cosmetic Products

With the increasing use of nanotechnology in the cosmetic industry, the safety of nanoscale ingredients and the transparent communication of their presence to consumers are being addressed specifically by regulatory authorities. In this context, both EU Regulation 1223/2009 (Regulation (EC) No 1223/2009) and the Turkish Cosmetic Products Regulation define specific notification and labeling obligations for products containing nanomaterials.

In this article, you will find a detailed overview of the required notification processes, technical data requirements, and labeling obligations for nano-containing cosmetic products.

When Should Nanomaterial Notification Be Made?

According to cosmetic regulations:

Products containing nanomaterials must be notified at least 6 months before being placed on the market.

This period is mandatory to allow regulatory authorities enough time to evaluate the safety of the nanomaterial in question.

Platforms for Notification

Before a nano-containing product is placed on the market, notification must be submitted through the following platforms:

For the European Union:

CPNP – Cosmetic Products Notification Portal

For Türkiye:

ÜTS – Product Tracking System

Both platforms evaluate nanomaterial notifications separately from standard product notifications and require more comprehensive technical data.

Required Information for Nanomaterial Notification

Since nanomaterials require a more detailed safety assessment than classical cosmetic ingredients, extensive technical data must be provided during the notification process. This information serves as the foundation for regulatory authorities to evaluate the safety of the nanomaterial.

The following dataset forms the basis of nano notifications made through CPNP and ÜTS:

✔ General Information

INCI name
IUPAC name
Function code (e.g., UV filter, colorant, antibacterial)
Annual quantity

✔ Particle Characteristics

Particle size
Size distribution
Particle shape (spherical, rod-like, plate-like, etc.)

✔ Surface Characteristics

Surface coating information (if present: type and percentage of coating)
Surface properties (surface charge, modifications, functional groups)

✔ Solubility and Catalytic Activity

Solubility/dissolution behavior (in water, oil, buffer solutions)
Catalytic activity (if applicable: reactivity or surface activity)

✔ Exposure Information

Rinse-off / leave-on status
Exposure routes (dermal, inhalation, possible risk scenarios)
Exposure conditions (frequency of use, contact duration, target population)

✔ Other Information

Toxicological Profile Document (TPD)
Safety Data Sheet (SDS)
Additional notes and assessments

Labeling Requirement for Products Containing Nanomaterials

According to cosmetic regulations, if a product contains a nanomaterial, the relevant ingredient must be indicated in the INCI list with the term “(nano)”.

Example:

Titanium Dioxide (nano)

This notation is mandatory to ensure consumer awareness and transparency.
If an ingredient is present in nano form but is not indicated on the label, it is considered non-compliant with regulations.

Regulatory Compliance Is Crucial for Nano-Containing Products

Although nanomaterials offer highly valuable benefits in cosmetic formulations, they require a comprehensive technical and safety evaluation process.

For a nano-containing product to be placed on the market, the following are mandatory:

Notification at least 6 months in advance
Submission of all required technical data without omissions
Correct labeling with the “(nano)” indicator

These requirements are essential both for protecting consumer health and ensuring that brands operate in full compliance with cosmetic regulations.

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