Frequently Asked Questions About Cosmetic Contract Manufacturing

According to Article 2 of the Cosmetics Law No. 5324, cosmetic products are defined as;

of the human body such as epidermis, nails, hair, lips and external genital organs, as well as to the teeth and oral mucosa, the sole or main purpose of which is to clean these parts, give them scent, change their appearance and/or correct and/or protect body odors or keep them in good condition.

How to Decide Whether a Product Is Considered Cosmetic?

The decision is made by evaluating the legislation of the product groups that the product may be included in within the scope of its features.

* Product composition

* Purpose of use

* Application place and method Presentation

* Mechanism of action

* Claims

* Other elements related to the product are examined as a whole.

Product Tracking System (UTS) is used to track all medical devices and cosmetic products manufactured or imported in Türkiye, from the production line to where they are sold and used, and to track them all the way to the end user.

In accordance with the Cosmetics Law No. 5324, it is mandatory to notify the Ministry’s Product Tracking System (ÜTS) platform in order to ensure product tracking before cosmetic products are placed on the market.

If a cosmetic product is claimed to be free of certain components/components, an analysis report from a laboratory that complies with TSE ISO IEC 17025 standards must be submitted to the Cosmetic Products Department during the application phase, stating that the product does not contain the substance/substances in question. Those who do not submit the document or prove that it does not contain the substance cannot use this “free” claim.

Natural Cosmetics: Cosmetic products that meet the natural cosmetic product requirements specified in internationally accepted natural cosmetic product standards, but do not have to be organic.

Organic Cosmetics: Finished cosmetic product that meets the requirements specified in internationally accepted organic cosmetic product standards.

In order to use the declarations of “organic” or “natural” for cosmetic products, their visuals or implied expressions and shapes in labels, packaging, written, verbal, visual etc. promotions, manufacturers must have documents proving that they meet the requirements of these statements.

Within the scope of the Guide on Cosmetic Product Claims, an analysis report from a laboratory that complies with TSE ISO IEC 17025 standards stating that the cosmetic product does not contain certain ingredient(s) must be submitted to the Cosmetic Product Department at the application stage.

Parabens that need to be checked are as follows;

• Methylparaben
• Ethyl paraben
• Propyl paraben
• Butyl paraben
• Hexamidine paraben

• Minor changes that do not change the product class do not require a new barcode. ( e.g. change of preservative, changes originating from the raw material supplier, etc.)
• If the brand changes, the barcode changes.
• If the quantity changes, the barcode changes.
• If the name changes in the same product, the barcode does not change. (Lavender soap → Lavender scented soap)
• If the formula changes, the change values are examined.
• If the claim changes, the function is examined.

(Lavender soap → Moisturizing lavender soap: Barcode does not change.)
(Anti- aging cream → Sunscreen cream: Barcode changes.)