Safety and claims assurance are main reasons why beauty and personal care brands must invest in proper testing, lest be caught up in myriad issues. Production miscues, inadequate sample size or representation in a clinical trial or consumer panel, data to rebut a claims challenge and class action lawsuits can all arise. A well-vetted testing provider will provide the tools, expert analysis and proper counsel to help your brand stay on track.

Issues shaping product formulation in 2023—such as clean beauty and greater representation as well as high-profile legislation like MoCRA—are top-of-mind for brands, and testing providers alike. 

Trending in Testing

Leading testing service providers have solutions in place to address shifting formulation demands, whether they come from consumers, retailers or regulatory bodies.

“One of the big issues that I’ve seen regarding home and personal care products is the reduction of allowable preservatives that can be used in formulations. Preservation changes impact microbial viability, meaning that microorganisms may be able to grow where they could not before,” noted Anne Wagner PhD, technology and market development manager, Charles River Laboratories Microbial Solutions.

“One way to control microorganisms in manufacturing is to use good manufacturing processes throughout production. Using environmental monitoring with tracking and trending and GMP processes will help establish and maintain control over your manufacturing environment, reducing potential microbial contamination events and increasing the safety of your products,” she said.

Charles River offers Celsis rapid microbial detection validation services to help brands get their rapid method implemented quickly and efficiently, noted Wagner.

“We offer services at competitive price points that range from providing protocols where you can do the validation yourself to full service complete packages where we can do the testing for you,” she said.

“With our Accugenix identification services, we offer tracking and trending software conveniently located on a secure online customer web portal. However you choose for us to help you, you are always backed by our renowned global customer service with technicians available in your region to train and help your employees virtually or on site.”

According to Neil Zimbaldi, creative director, Advanced Science Laboratories, consumers are increasingly demanding products that are eco-friendly and free of harmful chemicals and toxins.

“This trend toward ‘clean beauty’ drives companies to reformulate their products. At the same time, rigorous testing is often requested to ensure that products are safe, effective and deliver on their promises,” he said.

Advanced Science Laboratories, as an independent commercial testing lab, provides a fully customizable scope of study protocols to address clients’ specific claims, Zimbaldi asserted.

“We also utilize industry standard laboratory procedures specifically aimed toward cosmetic safety and hypoallergenic claims. What is unique about Advanced is the fact that all testing is performed in-house, we do not outsource. This, together with our open-door policy continues to be well-received by our clients,” he said.

Advanced Science Laboratories offers safety and efficacy testing as well as a wide range of in-vivo and in-vitro testing options. Antiperspirant and deodorant studies utilizing a calibrated temperature and humidity chamber are also available.

‘Clean’ Products, Diverse Panels

“The consumer’s desire for cleaner and more sustainable products continues in full force,” noted Tracey Baubie, president/CEO of Comprehensive Research Group, Inc. “This desire is clearly entrenched among Millennials and Gen Z populations, with no signs of slowing. This is good news for the environment, consumers and testing facilities alike.”

Another trend that does not appear to be slowing is the willingness of consumers to spend discretionary funds on beauty and personal care products.

“Even as manufacturers have raised their pricing, consumers appear willing to pay a little more, especially if the products they purchase have been claims tested. For consumers, claims testing provides added confidence that they are achieving professional grade care at home,” Baubie asserted.

Diverse Panels

The need for diverse panels continues to grow. For example, when testing its new Super Serum, Olay’s clinical study involved 200 women of diverse ethnicities and skin tones.

Baubie said CRG has had an uptick in demand; including requests for a wider variety of Fitzpatrick skin tones and hair texture. The company has expanded its grading capabilities, adding an additional five certified redness/dryness skin graders and a new dry scalp/dandruff (ASFS), for totals of seven and two, respectively.

“All graders have gone through rigorous training and certification by independent experts in the field. These additional capabilities will enable us to conduct more simultaneous studies, something our 14,000 square foot state-of-the-art facility can easily accommodate,” Baubie noted.

“There is increasing interest in more diverse clinical panels, with and without before and after pictures,” noted Craig Weiss, president of Consumer Product Testing Company, which has added to all of its departments to continue offering customers best-in-class options.

Consumer Product Testing Company opened a satellite clinic to increase its volunteer panel size and diversity, noted Weiss, who last month shared expert insight at the National Advertising Division (NAD) Annual Conference: What’s New + Next in Ad Law. Weiss was on the dais during a claims substantiation panel.

In addition to the satellite clinic, Consumer Product Testing Company added in-vitro sensitization testing to its in-vitro department and increased the chemistry department’s stability chambers capacity as well as the size of its microbiology lab.

Weiss noted more preservative issues as well as more anhydrous products requiring different testing.

Competitive Edge

With greater competition, more beauty and personal care companies are going deeper in regard to the validation and testing processes.

Customers are looking to differentiate themselves in an already overcrowded market, according to Jane Tervooren, vice president, Validated Claim Support (VCS). She told Happi there’s been an increase in requests for more creative visual representation of product efficacy which is one of its competencies.

“We are widely regarded as delivering the highest quality photography in the industry. The demand for diverse subject panels have become the norm, and requests for exploratory microbiome testing as a legitimate concern as opposed to just a ‘seal of approval’ has gone through the roof,” noted Tervooren. “We are happy to say that we’re seeing a trend from our clients that suggest they are not just interested in meeting legal requirements but about prioritizing the well-being of consumers.”

According to Brian Ecclefield, managing director at VCS, companies that prioritize lab testing send a clear message that they value skin health.

“This commitment can differentiate their brand in a competitive market, earning them a loyal customer base. The combination of safety and efficacy testing tell a story of a brand that not only respects its customers but values their opinions and continued well-being,” he said.

VCS in September closed a “significant round” of financing that will allow it to continue to grow while staying 100% privately held.  Through this debt raise, VCS will be able to increase its clinical staffing and provide additional “cutting-edge outlets for claim support,” according to Ecclefield.

Among its recent investments, VCS added Canfield Visia CRP generation 5 with primos 3D analysis that enhances the offerings from its clinical photography department. In addition, VCS is now collaborating with Helioscience, an FDA registered in-vivo and in-vitro testing lab in France.

“Together we share a common desire to help promote the effectiveness, safety and credibility of SPF, skincare and cosmetic products for leading brands. We can assist with ISO and FDA in-vivo methods as well as the most consistent, reproducible in-vitro test based specifically on the consistency/type of product being analyzed. This provides a very cost-effective way of combining in-vitro determination of critical wavelength or broad-spectrum claim support, and an accurate, estimate of in-vivo SPF,” said Ecclefield.

While speed is important, leading providers of testing services keep accuracy front and center.

“Our role in safety testing at IVRO has always focused on accuracy first, speed of response to benefit our customer next,” noted W. Richard Ulmer, chairman and CEO of InVitro International, which has long been focused on alternatives to animal testing.

“We feel blessed to deal with many ethical cosmetic and chemical companies who care about minimizing testing on animals,” said Ulmer.

MoCRA’s Arrival

When it comes to legislation, the beauty industry has been focused on MoCRA (the Modernization of Cosmetics Regulation Act).  Testing experts have been keeping a keen eye on how this new legislation may impact their customers.

“MoCRA is one of the most significant changes to FDA authority over cosmetics since 1938 with the FD&C Act. That doesn’t mean there hasn’t been any changes in between those years, but this is the biggest change we’ve seen in a very long time,” noted Wagner of Charles River. “This could mean a lot of change to cosmetic manufacturers. Many may be forced to modernize and renew focus on documentation and control.”

Wagner said these changes will be demanding, especially for smaller to medium-sized manufacturers because they have fewer people and teams to cover this increased quality demand.

“These changes are not meant to enforce unnecessary burdens on cosmetic manufacturers,” she added. “They are meant to help ensure product quality and transparency to the consumer.”

As the vendor for the Celsis rapid microbial detection system and Accugenix microbial identification services, Charles River can help customers deal with some of the changes required by MoCRA, Wagner said.

A major change that will be enacted by the end of 2023 is the records access section that includes safety substantiation.

“A Celsis rapid microbial detection system offers objective and clear reports that are 21 CFR Part 11 compliant and can integrate into your own LIMS, making acquiring those documents substantially easier,” she explained.
“With our Accugenix identification services with our data tracking and trending you can proactively understand and document your manufacturing environment, aligning with the new MoCRA Good Manufacturing Process requirements currently in the draft phase.”

Weiss of Consumer Product Testing Company also weighed in on MoCRA.

“I believe the impact may be great as the safety standard is elevated to a non-injurious under conditions of use. I think this requires a more extensive safety testing program and a Tox Risk Assessment (TRA) may be necessary. Additionally, since we don’t know if the agency will accept CIR findings for ingredients, the TRA may need to be more intensive than is typically conducted now,” he asserted.

MoCRA compliance seems to be of interest to a much broader group of companies that now inquire about testing compared to earlier in the year, noted Zimbaldi.

“We believe the expansion of safety requirements will have a positive impact on the industry and will be beneficial to the average consumer,” he said.

According to Zimbaldi, services frequently requested based on MoCRA include repeat insult patch tests, phototoxicity and comedogenicity. His company has also had multiple requests for variations of these studies, such as single application 24-HR, 48-HR and 72-HR patch tests and skin compatibility and controlled and uncontrolled use tests.

“Because MoCRA’s overarching focus is to ensure safe products, it would not be surprising to see an uptick in clinical testing, especially in safety-in-use testing and product release testing. Time will tell,” said Baubie.

Ulmer told Happi, “We see this Act as adding to confidence as well as costs for consumers; then adding costs and time to reach the market for industry in general. The age-old question of whether the benefits outweigh the disadvantages will remain controversial.”

Some unknowns remain, however.

According to VCS, while FDA has called for all products to have relevant and sufficient safety data under MoCRA, there is no hard/fast set of requirements or guidelines as to what types of irritation or dermal safety testing are suitable for particular product categories. And there’s no mention about assurance the products actually perform, VCS officials note.

“There is no guidance whatsoever, regarding whether in-vitro testing is acceptable (cell cultures or alternative skin), or if eye area products will require in-vivo instillation testing. In our industry, HRIPTs are commonly used for topical skincare safety and dermal irritation; however, there is also no mention of whether this would necessarily suffice for facial care products. With haircare there is really no tried and true industry standard and often customized in-use safety or modified dilutional patch testing is requested at the retail or distribution level,” asserted Ecclefield.

Uncertainties will not hold up testing providers from delivering what customers need.

“While we’re still waiting to hear about what specific in-vivo safety testing requirements may be recommended or required, we are confident that our preemptive voluntary registration and our extensive regulatory knowledge will be extremely useful,” said Ecclefield.  “As always, we’ll continue to be a resource for all types of testing, utilizing our massive network of trusted colleagues and partner labs who go above and beyond.”  

More Reading: Olay’s New ‘Chaosity’ Measurement

In the product development process for its new Super Serum,  Olay wanted to demonstrate the “supercharged” power of its new activated niacinamide—which it says offers “best-in-class” even skin tone efficacy and is proven to improve skin texture.
The team had to first develop a way to accurately measure the irregularity of skin, according to Dr. Rolanda Wilkerson, principal scientist, Olay North America. To read more about this, click here.

---

Testing Providers

Below are providers of testing services for the beauty, personal care and household products categories. For more information about the company, please reach out directly using the contact information provided.

Advanced Science Laboratories, Inc.
New City, NY
845-634-1500
info@advancedsl.com
www.advancedsl.com
Advanced Science Laboratories, Inc. is an FDA registered, ISO 9001:2015 certified and GCP compliant clinical testing and claim support laboratory headquartered 35 miles outside midtown Manhattan. We provide custom tailored study protocols to address any of your unique claims.

Allergisa/ALS Group
Campinas, SP, Brazil
+55 19 3789 8610
negocios@grupoinvestiga.com
www.allergisa.com

Ametek Brookfield 
Middleboro, MA 
508-946-6200
www.brookfieldengineering.com

BioScreen Testing Services, Inc
Torrance, CA 
310-214-0043
info@bioscreen.com
www.bioscreen.com

Certified Laboratories for Cosmetics, OTC & Supplements
Burbank, CA
818-845-0070
COS-inquiries@certifiedgroup.com
www.certified-laboratories.com

Charles River Laboratories Microbial Solutions
Charleston, SC
1-877-CRIVER-1 | 877-274-8371
askcharles@criver.com
www.criver.com
As a partner for microbial quality control, the Charles River portfolio of Celsis microbial detection and Accugenix microbial identification solutions provide the products and services needed to confirm the safety and quality of home and personal care products while maintaining an efficient and profitable manufacturing process.

Comprehensive Research Group, Inc.
Minneapolis, MN
612-781-3400
tbaubie@crginc.org
www.crginc.org
For more than 30 years, CRG has provided quality data to the world’s leading manufacturers of personal, beauty and baby care products.  It is our sole focus. We deliver superior study execution and data collection for product development efficacy and claims testing, as well as safety-in-use testing.

Consumer Product Testing Company
Fairfield, NJ
973-808-7111
sales@cptclabs.com
https://cptclabs.com
Consumer Product Testing Company is a world-renowned, global leader in the contract laboratory testing of cosmetics, personal care, pharmaceuticals and specialty chemicals. Since 1975, we have assisted clients with their testing needs from conception to completion.The services offered include clinical safety and performance claims validation, photobiology, analytical chemistry, microbiology, in-vitro safety and consulting services. We are an ISO/IEC 17025:2005 accredited lab.

Eurofins | EAG Laboratories
San Diego, CA
877-709-9526
www.eag.com

Eurofins | CRL, Inc.
Piscataway, NJ
732-981-1616
info@crlresearchlabs.com
www.CRLResearchLabs.com

Genemarkers, LLC 
Kalamazoo, MI 
844-220-6231
info@genemarkersllc.com
www.genemarkersllc.com

InVitro International 
Placentia, CA
invitro@invitrointl.com
www.invitrointl.com
InVitro International, founded in 1985, is a technology/customer driven provider of non-nnimal testing methods. IVRO tests are designed to produce eye/skin irritation & skin corrosivity OECD/GHS Regulatory level results to replace/reduce animal or human tests, IVRO offers both laboratory services and test kits.

Princeton Consumer Research
St Petersburg FL / Raritan NJ
727-576-7300 / 609-455-1112
info@princetonconsumer.com
www.princetonconsumer.com

Q Laboratories, Inc.
Cincinnati, OH 
513-471-1300
office@qlaboratories.com
www.qlaboratories.com

RCTS, Inc.
Irving, TX
972-871-4371
barry.reece@alsglobal.com
barry_reece@rctslabs.com
https://rctslabs.com

Skinobs Platforms
Aix-les-Bains, France
+33(0)7 88 17 00 14
contact@skinobs.com
acharpentier@skinobs.com
www.skinobs.com

Solar Light Company, Inc. 
Glenside, PA
215-517-8700
www.SolarLight.com

Validated Claim Support, LLC
Teaneck, NJ
201-331-9300
sales@validatedcs.com
https://validatedcs.com
VCS is an FDA registered and inspected, privately-held clinical testing site in Teaneck, NJ. Specializing in expert grading, biophysical instrumentation, consumer perception and visual claims, we provide novel testing methods & top-notch photography to help build consumer trust. Experience the best customer service in the industry and contact us today.

Zurko Research
Madrid, Spain 28023
+34 91 521 15 88
info@zurkoresearch.com
www.zurkoresearch.com
Zurko Research is a leading European CRO with more than 16 years of experience, specialized in in vivo, in vitro and ex vivo testing, as well as regulatory strategy consultancy services.