Before You Formulate, Get Your Documents in Order

We recently heard from a fellow manufacturer who had just been handed a formula by a new customer. The customer was very proud of the formula: it performed well, it felt great, and their volunteer test group loved it. There was just one problem: they wanted COSMOS certification through Ecocert, but the formula as developed did not meet the standard’s requirements. The original formulator hadn’t checked those requirements before the formula was built. Now this customer is facing a choice between reformulating (which means new stability work, additional testing, and a delayed launch while that work is completed) or giving up the certification they wanted in the first place. 

This happens more often than you'd think, and it's almost always avoidable. Avoiding this starts with clear requirements and ingredient documentation before formulation. 

Formulate to the Finish Line, Not From the Starting Line 

Most formulation problems that show up late in a project were actually decided early, before a single ingredient was weighed. If you know where a product needs to end up, you can build the path backward from there: 

Which market(s) will it sell in? US, Canada, EU, and Korea all have different documentation and ingredient requirements. 

Which certification(s) does the brand want? Standards and programs such as COSMOS, NATRUE, organic certification, and cruelty-free certification each have their own requirements. Identify the specific standard or program, then confirm what ingredient, sourcing, and supplier documentation it requires. 

What claims will go on the label and the website? "Vegan," "no added sulfates," and "made in the USA" all need support you can produce on request. 

Those answers can affect ingredient choices, sourcing, manufacturing, documentation, and label wording. That’s why these questions need to be answered before formulating starts, not after. 

Essential Ingredient Documents to Gather Before Formulation 

Here’s the starting checklist we recommend reviewing for each raw material before it goes into a development formula. Which documents you need will depend on the ingredient, your target markets, and your certification goals. 

Certificates of Analysis (COAs)

Lot-specific test results showing how the material compares with its specifications. If a supplier can't provide one, that's information too. 

Safety Data Sheets (SDS)

Safety Data Sheets provide information about hazards, handling, and storage. Request them where applicable to the material; they may also be requested during certification audits.

INCI Names and Composition Breakdowns

Trade names hide a lot. A "natural preservative blend" might contain a component that disqualifies the whole formula from a certification. You need to know what's actually inside every blend, base, and botanical extract. 

Ingredient Origin and Processing Statements

Vegan status, animal-derived/byproduct content, GMO status, and extraction method. Many certifications restrict not just what an ingredient is but how it was made. 

Certification and Conformity Documentation

If certification is a goal, check every raw material against the chosen standard’s requirements before including it in the formula. Obtain the supplier documentation needed to support that review, and confirm any uncertainties with your certification body. Ingredient eligibility is one part of certification; manufacturing, packaging, and other requirements may also apply. Certification also doesn’t replace the safety and labeling requirements that apply wherever you plan to sell.

Allergen and Restricted Substance Information

Fragrance allergen declarations, International Fragrance Association (IFRA) Certificates of Conformity for fragrance mixtures where applicable, and relevant restriction information for essential oils and other scent materials, plus documentation for any ingredients with regulatory limits in your target markets.

These documents help you evaluate ingredients, but they don’t establish the safety of the finished product on their own. You’ll also need a plan for evaluating and documenting the finished formula’s safety.

Share Your Requirements With Your Contract Manufacturer

If you're partnering with a contract manufacturer (CM), it's essential to communicate your certification requirements before formulation begins, as those requirements directly influence how the product is formulated. 

Every raw material selection, preservative choice, and fragrance decision needs to take those requirements into account. Finding out later that a finished formula doesn’t qualify can mean changing ingredients, repeating testing, and pushing back your launch.

And here's a useful vetting tip: pay attention to the questions they ask at the beginning. A reputable CM should be asking you these questions up front. If your CM is willing to begin product development without understanding where the product will be sold, what certifications it needs to meet, and what claims you intend to make, that's a red flag. Before discussing texture, fragrance, or other formulation details, the first question should be: “What does this formula need to comply with?" Those requirements shape every subsequent development decision. 

If you're your own manufacturer, the same rule applies, but now you are responsible for both roles. Get your documents in order before you start the formula. Confirm your certification standards, obtain the necessary documentation from your suppliers, and verify every ingredient against your requirements. Compliance is easiest to build into a formula from day one and much harder to add after the fact.  It's much easier to be your own toughest gatekeeper at the start of a project than to be your own disappointed client at the end of one. 

Why Documentation Matters for Custom and Semi-Custom Formulation

When a client brings us a formula or asks us to develop one, the documentation conversation happens at the very beginning of the project. Not because we love paperwork, but because we've seen what happens when it comes last. A formula that can't be certified, can't be exported, or can't support its own label claims isn't finished. It's a liability with a nice texture. 

The good news is that none of this requires special expertise to start. It requires asking your suppliers for documents they should already have and asking your clients where the product needs to end up before development begins. Brands that do this are better positioned to set realistic launch dates and avoid preventable delays. Those that don’t may find themselves revisiting and reformulating products that otherwise seemed ready to move forward. 

Prepare First, Then Formulate

The best formulas aren’t just well designed. They’re well prepared. Formulation is the fun part, and it's tempting to jump straight in. Time spent gathering documentation up front can prevent weeks of rework later. Define the destination, collect the paperwork, verify every ingredient against it, and then formulate. Your future self, your clients, and your launch timeline will thank you. 

If you're planning a product and aren't sure what documentation you'll need, that's exactly the kind of conversation we like to have early. Reach out to NourishUs Naturals before you formulate, not after.