In 2025, cosmetic ingredient sourcing in Europe is at a turning point. A wave of regulatory change is coming, which Cosmetics Europe calls a “regulatory tsunami”. REACH revisions are due by the end of 2025, and updates to the EU Cosmetics Regulation are expected soon.
At the same time, documentation demands are increasing. For procurement teams, the stakes are high: can you trust the documents you receive, or will gaps lead to disruptions?
Regulatory Overhaul for Cosmetic Ingredient Sourcing
The European Commission is reviewing the EU Cosmetics Regulation 1223/2009. A REACH reform proposal is also in progress. This includes shorter registration validity (ten years), expanded polymer requirements, and mandatory Digital Product Passports (DPPs).
Changes like Commission Regulation (EU) 2025/877 will start on 1 September 2025, tightening bans on CMR substances and other ingredients.
GMP Expectations Remain High:
- EU law (Regulation 1223/2009, Article 8) requires adherence to Good Manufacturing Practices. Compliance with ISO 22716 shows GMP conformity.
Documentation Obligations:
- Responsible Persons must keep detailed Product Information Files (PIFs). This includes safety assessments, CoAs, and proof of GMP compliance, accessible for at least ten years.
Supply chain documentation is rising as firms prepare for more digital tools like DPPs and digital SDS.
Key Challenges for Procurement Teams in 2025
- Regulatory Complexity & Shifting Deadlines
- Multiple reforms (Cosmetics Regulation, Fitness Check, and REACH updates) create fluid timelines, making supplier documentation delays risky.
- GMP Certification Ambiguity
- Not all suppliers adopt ISO 22716 or provide the necessary PIF documentation. This leaves procurement unsure if products meet GMP standards.
- REACH and Registration Validity Risks
- If supplier REACH dossiers lose validity, procurement may struggle to find compliant alternatives, especially as registration periods shrink.
- Inconsistent CoAs and Chain-of-Custody Data
- Variations in formats and completeness hinder internal reviews, especially regarding chain-of-custody transparency.
- Variations in formats and completeness hinder internal reviews, especially regarding chain-of-custody transparency.
How CheMondis Strengthens Cosmetic Ingredient Sourcing
CheMondis offers a technology-enabled, expert-backed supplier discovery platform that clarifies documentation without overpromising.
- AI-Powered Data Aggregation: Quickly access supplier information globally, highlighting GMP compliance (per ISO 22716), REACH registration status, and CoA availability.
- Expert Curation: Our compliance team verifies documentation, ensuring authenticity amid regulatory complexity.
- Transparent Supplier Profiles: Differentiate between manufacturers and intermediaries, show chain-of-custody details, and flag potential weaknesses (e.g., approaching REACH expiry).
- Balanced Sourcing Support: Connect with global suppliers while meeting European documentation standards
With CheMondis, procurement teams gain greater supply chain compliance visibility, enabling quick, confident sourcing decisions.
Practical Steps for European Procurement Teams
- Use a Documentation Checklist
- Current REACH registration numbers, CoAs, and indications of DPP or digital SDS when relevant.
- Prioritize Supplier Transparency
- Note if the supplier is the manufacturer or a distributor. Request upstream documentation or audit evidence.
- Track Regulatory Reform Timelines
- Align sourcing cycles with known deadlines, like REACH reform or the 1 September 2025 implementation of Regulation 2025/877.
- Mitigate Supply Risk with Verified Partners
- Especially when sourcing from high-volume markets, they require documented REACH compliance, chain of custody evidence, and timely CoAs to reduce disruption risk.
Strategic Takeaway: Turning Documentation into Competitive Advantage
In 2025, successful cosmetic ingredient sourcing in Europe depends less on price and more on the ability to verify documentation and compliance proactively. Uncertainties around GMP, REACH registration, and ingredient bans require clear visibility. Procurement teams that can quickly assess and trust supplier documentation will position their brands ahead of disruptions.
