What is a 'Variant' at General Cosmetic Safety?
At GCS, we allow variants to be placed into the same CPSR as a base formulation, if the following conditions are met:
- base formulation is identical (same ingredients and same amounts)
- the additions add up to <2% for leave-on products and <4% for rinse-off products
- ingredient types: colourants, scents (fragrance oils or essential oils), botanical extracts (<0.2%) or clays.
[Contact the assessor for any other combinations]
How to describe the percentage amounts of variants.
Scenario 1
Where the amount of additions is the same, calculate the base as part of the total mixture i.e.:
Variant 1: 2% total
Variant 2: 2% total
The base should add up to 98%.
Scenario 2
Where the amount of additions is not the same, calculate the base as 100% i.e.:
Variant 1: 2% total
Variant 2: 1.5% total
The base should add up to 100%.
About the Author

Geraldine Garrs is a member of the Royal Society of Chemistry, CTPA, British Toxicology Society and the Society of Cosmetic Scientists. Geraldine is an independent Cosmetic Safety Assessor and Chartered Chemist with over nine years of experience helping more than 700 brands ensure their cosmetic products are safe and compliant. She specialises in preparing Cosmetic Product Safety Reports (CPSRs) for UK and EU. Geraldine is passionate about supporting small cosmetic businesses and simplifying complex regulations. Learn more at www.generalcosmeticsafety.co.uk
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Qualifications: CChem (Royal Society of Chemistry). MSc (Distinction), University of Strathclyde, BSc (Hons) Chemistry, University of Nottingham and Certificate – Safety Assessment of Cosmetics in the EU, Vrije University Brussels