Lab Tests for a CPSR: Which Ones, and Who Runs Them

Which lab tests for a CPSR exist, and what does each show?

The laboratory tests named in Eldris's answers are stability, challenge, SPF and microbiology, each carried out by a testing laboratory.

A stability test shows how the product holds up in its pack over time. A challenge test, run to ISO 11930, checks whether the preservative system protects the product against contamination. A microbiology test checks the product for unwanted microbes. An SPF test measures the sun protection a product gives.

The test reports you supply go into the PIF, and the safety report is based on the formula, test data and documents you provide. Eldris does not ask for every test for every product: it asks for a challenge test report only for products that contain water. That is the only one of the four with a stated rule in Eldris's answers. This page does not say which tests your formula needs. Stability data and a challenge test are on the list of documents that help but are not needed to start.

Does Eldris run or arrange any of them?

No. Eldris does not carry out, arrange or recommend laboratory tests, and it names no laboratory.

Laboratory tests are not in the per-formula fee shown on the pricing page. A testing laboratory carries out each test and sets the price, so you agree the test and its fee with the laboratory directly. Eldris prints no test prices for that reason. The per-formula fee includes the signed CPSR (Part A and Part B), the PIF, the Article 19 label review and the INCI ingredient list for one formula, whatever the number of ingredients. Test reports you obtain are uploaded in your Eldris portal.

What Eldris does is prepare the CPSR and PIF through its CPSR and PIF service from the formula, the test data and the documents you provide. At Eldris, a qualified safety assessor signs the CPSR, Part A and Part B. Eldris is not a testing laboratory. Choosing a laboratory is your decision. After you pay and upload, Eldris tells you what is still missing, without pointing you to a laboratory.

When does Eldris ask for a challenge test, and can it wait?

Eldris asks for a challenge test report (ISO 11930) for products that contain water, not water-free ones, but you can start your order without it.

This is a statement of Eldris's service, not a provision of the Regulation, so it should not be read as law. Whether your product contains water is one of the first answers Eldris asks for, together with alcohol or solvents, fragrance and the packaging material.

For a water-free product, Eldris asks for no challenge test. For a product with water it asks for one, but the order can start before the laboratory report exists. Starting the order means paying and then uploading your documents in your Eldris portal. The laboratory sets the price of the challenge test. Upload what you have and Eldris tells you what is still missing for your formula. The 5–10 working days run from the day Eldris has your complete documents. The short answer is also in the FAQ hub: which lab tests you need and whether Eldris runs them.

What about stability, microbiology and SPF tests?

Stability data helps but is not needed to start. Microbiology and SPF results are not on the start list either.

No laboratory report is needed to start an order. Stability data and a challenge test help but are not needed to start, and no microbiology or SPF result is asked for at the start. The water rule is the only test rule in Eldris's answers: a challenge test report for products that contain water. This page does not say that any other test is waived for a water-free product, or that any other test is required.

A testing laboratory carries out stability, microbiology and SPF tests. A different SPF level usually needs its own CPSR, which Eldris prices as a formula and discusses with you first. If the safety assessor needs a result you do not have, the question appears in your portal, and the 5–10 working days start again from the day you answer.

How do test results reach the safety report?

The CPSR rests on the formula, test data and documents you provide; the test reports you supply go into the PIF.

Article 10(1) asks for a safety assessment on the basis of the relevant information. Annex I sets the CPSR out as Part A, the safety information, and Part B, the safety assessment. At Eldris, a qualified safety assessor signs the CPSR, Part A and Part B. The Responsible Person keeps the PIF for ten years after the last batch is placed on the market.

In Great Britain a cosmetic may not be placed on the market unless a Responsible Person is established in the UK. That rule is in Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019. The Responsible Person keeps a PIF in English that includes the product safety report, as GOV.UK guidance explains. If you hold reports from a manufacturer or another market, what the CPSR and PIF contain covers where they fit.

Frequently asked questions

Who pays the laboratory?

You do. A testing laboratory sets the price of each test, and laboratory tests are not in the per-formula fee shown on the pricing page. Eldris does not name or recommend a laboratory, so you choose one and agree the fee with it.

Who arranges a test if the assessor asks for one?

You do, with a testing laboratory of your choice. The question appears in your portal, and the 5–10 working days start again from the day you answer. Eldris does not arrange or recommend laboratory tests.

Do I need a challenge test for a water-free product?

No, Eldris does not ask for one. It asks for a challenge test report (ISO 11930) for products that contain water, not water-free ones. Your answer on water is one of the short answers Eldris asks for at the start, with alcohol or solvents, fragrance and the packaging material.

Can I place the order before the tests are finished?

You can start without a challenge test or stability data, because both help but are not needed to start. After you pay, upload what you have and Eldris tells you what is still missing, and the 5–10 working days run from the day Eldris has your complete documents.

Is the water rule for challenge tests in the Regulation?

The water rule is a statement of Eldris's service, not a provision of Regulation (EC) No 1223/2009. Article 10(1) requires a safety assessment on the basis of the relevant information.

Does Eldris run SPF tests for sun products?

No. SPF tests are done by a testing laboratory, which sets the price. A different SPF level usually needs its own CPSR, which Eldris discusses with you first.

Is a packaging compatibility test needed?

A packaging compatibility test is not among the tests Eldris names. The packaging material is one of the short answers asked at the start. If the safety assessor needs more, the question appears in your portal.