Quick Answer: New Zealand cosmetic ingredient review needs the actual formula, reliable substance identities and the intended product use. Screen against the current EPA prohibited, restricted and allowed-ingredient schedules, and separately check the medicines boundary. Review concentrations, use conditions and supplier evidence together. The 2026 updates and later PFAS and homosalate transitions make an old ingredient checklist insufficient for a new commercial batch.
MOOYAM editorial content. Last reviewed: 14 October 2026. Cover: AI-generated editorial illustration.
Review the formula as a controlled technical record
A retail ingredient list is an important output, but a technical ingredient review needs more information. Establish the formula version, ingredient identities, concentrations, functional roles and intended application. Include relevant composition information for blends rather than treating a trade name as a complete identity. A reviewer cannot reliably screen a preservative blend when its constituent substances are unknown.
Create one master formula reference for the project. Connect raw-material specifications, supplier statements, artwork and batch instructions to that reference. If two documents use different version numbers, resolve the difference before the reviewer starts. Otherwise, a well-written assessment may accidentally describe a product other than the one that will be manufactured.
For a commercial overview, read a neighbouring-market launch planning guide. The separate a neighbouring-market compliance planning guide explains the relationship between the EPA workstream and product categorisation. This article focuses on the practical information needed for ingredient screening.
Use the current EPA schedule structure
The EPA updated rules guidance identifies Schedule 4 as prohibited ingredients, Schedule 5 as restricted ingredients, Schedule 6 as allowed colourants, Schedule 7 as allowed preservatives and Schedule 8 as allowed UV filters. It says those schedules were updated for the rules effective on 1 January 2026. Check the current legal entries rather than relying on an archived marketing checklist.
A screening result should record the entry and conditions examined. The ingredient’s function, product type, application area, concentration and any applicable warnings may affect the assessment. This guide deliberately does not reproduce numerical limits for individual substances: those must be verified in the current legal instrument for the proposed use.
EPA provides a searchable spreadsheet as an aid, while identifying the schedule documents as the legal instruments. Use search tools to find a candidate entry, then confirm the authoritative wording and relevant conditions. Record synonyms considered so a failed search for a familiar INCI name does not become an unsupported “not restricted” conclusion.
| Workstream | Official source | Review question |
|---|---|---|
| Cosmetic composition | EPA cosmetic group standard | Which current conditions apply to this formula? |
| Product categorisation | Medsafe guidance | What do ingredients, purpose and claims imply? |
| Commercial implementation | Assigned project parties | Who holds evidence and approves release? |
Resolve identities and concentrations before signing off
Ask suppliers to identify the substance behind each trade name, with appropriate technical identifiers and composition details. Where identity is ambiguous, request clarification before assigning a screening outcome. Two similarly named materials can differ in composition, grade or intended use. A reviewer should be able to trace the conclusion back to the material actually purchased.
For blends, calculate the relevant finished-product concentration from the complete composition and use level. Account for a substance contributed by more than one raw material. Record the basis of the calculation and unresolved supplier ranges. Do not substitute an assumed average when a restricted ingredient could sit at a different level within the declared range.
Document the application context. Leave-on and rinse-off formats, eye-area application and other use patterns should be described accurately for the reviewer. Changing the directions can alter the exposure and conditions that need assessment. A formula intended for one use should not be silently repurposed for a second product page.
Screen PFAS as a specific transition question
EPA’s guidance states that PFAS is being phased out, with import and manufacture prohibited from 1 January 2027, sales from 1 January 2028 and disposal required by 30 June 2028. The relevant definition and full conditions are in the group standard. Obtain a substance-specific assessment rather than inferring absence from a short consumer-facing ingredient declaration.
Ask for a supplier statement tied to the supplied material and the applicable definition. If the statement says only “no intentionally added PFAS,” clarify what that wording establishes and what it leaves unanswered for the review. Avoid converting a limited supplier assertion into an unlimited finished-product claim.
Keep the screening decision linked to replacement planning. A proposed substitute should be reviewed for its own composition and performance. Recheck stability, compatibility and other relevant evidence according to the assessment; do not assume a substitute is suitable simply because it resolves one ingredient concern.
| Input | Purpose | Suggested owner |
|---|---|---|
| Controlled formula and raw-material identities | Enable composition screening | Manufacturer and suppliers |
| Intended use and complete claims | Support category assessment | Brand and local reviewer |
| Current-rule conclusion | Record applicable conditions and dates | Relevant New Zealand party and reviewer |
| Final artwork and batch reference | Connect assessment to commercial stock | Brand and manufacturer |
Separate UV-filter and medicine-boundary checks
EPA publishes a separate transition for cosmetics containing more than 10% homosalate: import/manufacture from 1 July 2027, sale from 1 July 2028 and disposal before 1 April 2029. Confirm the actual product category and applicable conditions before using that timetable. A transition for this ingredient is not a general permission for every sunscreen formula.
The Medsafe categorisation guidance also requires attention to scheduled medicines and controlled drugs. Cosmetics cannot contain the categories identified in that guidance, and therapeutic claims are not permitted for products supplied as cosmetics. Ingredient screening and claim screening therefore need to communicate with each other.
If the product’s intended purpose raises a categorisation issue, resolve it before finishing an ordinary cosmetic review. A substance appearing in an EPA schedule is not, by itself, a conclusion that every concentration, purpose and commercial presentation is suitable. Ask the reviewer to document which framework and use were assessed.
Assess supporting evidence without inventing universal tests
Choose evidence according to the formula and the question being addressed. Relevant raw-material specifications, COA, SDS and supplier composition statements may support identity and quality review. Finished-product testing may be needed for particular stability, microbiological or compatibility questions. The appropriate programme depends on the product and assessment; one list should not be presented as universally mandated.
Read report scope carefully. Check the tested formula, sample reference, packaging, method, conditions and conclusion. A report on a similar base does not automatically establish performance for a fragranced, differently preserved or differently packaged commercial version. Ask the technical reviewer whether the differences matter.
Use private label skincare development discussions to agree the available evidence and any new work. Request the actual deliverables and limitations in writing. This avoids a situation where the buyer expects a finished-product assessment while the quotation covers only manufacturing and routine batch documentation.
Translate the assessment into artwork and change control
Once the reviewed formula is fixed, verify the ingredient declaration and applicable directions or warnings against that version. Check cartons, bottle labels and online product descriptions together. Do not let a design revision silently remove information that the reviewer considered necessary. Keep the final proof in the same controlled file as the formula assessment.
Establish a supplier change notification process before production. Changes to ingredient source, grade, blend composition, fragrance or use level should be assessed through the agreed workflow. A material described as “equivalent” may still affect identity, restrictions, impurity information or supporting test relevance. Record the reason for accepting each substitution.
The finished batch release should reference the approved material list and formula version. If a discrepancy appears, hold the decision open until the technical contact resolves it. A batch record and a reviewer’s conclusion are most useful when both describe the same product, rather than neighbouring versions of a development project.
Work with the manufacturer on the exact evidence request
MOOYAM can discuss OEM/ODM formulation, ingredient sourcing, packaging and technical records available for the project. Provide the target market, intended product use and the local reviewer’s questions early. A precise request helps the technical team identify whether it can supply an existing document, obtain a supplier statement or arrange additional work.
Contact the team through the MOOYAM project enquiry page with the formula development stage and required evidence scope. Keep local regulatory conclusions assigned to the appropriate New Zealand parties and reviewer. Manufacturing collaboration supports the assessment by supplying traceable inputs for the actual product.
Frequently asked questions
Which EPA schedules should an ingredient reviewer check?
EPA identifies Schedules 4–8 as prohibited ingredients, restricted ingredients, allowed colourants, allowed preservatives and allowed UV filters. Confirm the current legal entries and conditions for the product’s intended use.
Is an INCI list enough for formula screening?
Usually the reviewer needs additional controlled technical data, including concentrations and blend composition. Agree the necessary disclosure route with the supplier and reviewer.
What are the published PFAS transition dates?
EPA guidance gives 1 January 2027 for import/manufacture, 1 January 2028 for sales and 30 June 2028 for disposal. Confirm the legal definition and conditions for the specific product.
Does a supplier statement prove every ingredient is permitted?
Only within its actual scope. Review identities, concentrations, uses and the relevant current conditions. Clarify ambiguous or limited statements before recording a conclusion.
Should a reformulated product reuse its old evidence file?
Retain the history, but assess whether each report and decision still applies. Connect revised formula, materials, artwork and batch release to a new controlled version.