I. Objective

The purpose of these specifications is to regulate the use of the “Vegan” claim that may be mentioned on certain Laboratoires Novexpert brand products.

II. Regulatory Framework

In Europe, vegan cosmetic products are, like all cosmetic products, subject to the cosmetic regulation (EC) No 1223/2009, and must therefore meet the same quality and safety requirements as a normal cosmetic product. However, there is no specificity associated with the “vegan” criterion.

The products of Novexpert laboratories as well as the raw materials used by Novexpert laboratories comply with the relevant legislation, in particular the European regulation on cosmetic products (EC N°1223/2009) as amended and the Commission regulation on claims (N°655/2013).

III. Scope

To be certified Vegan, these products must meet the criteria defined for :

  • Origin and processing of ingredients
  • Composition of the finished product
  • Manufacturing and packaging
  • IV. Definitions

In the context of this specification, the following definitions apply.

Cosmetic ingredient – (definition taken from Regulation (EC) No 1223/2009)

Any chemical substance or preparation of synthetic or natural origin used in cosmetic products. The following shall not be considered as ingredients:

impurities in the raw materials used,

-subsidiary technical substances used in the manufacturing process, but which do not end up in the finished product.

Cosmetic product – (definition taken from Regulation (EC) No 1223/2009)

Any substance or preparation intended to be placed in contact with the superficial parts of the human body (epidermis, hair and capillary systems, nails, lips and external genitalia) or with the teeth and oral mucous membranes with a view, exclusively or mainly, to cleaning, perfuming, modifying the appearance of, protecting, maintaining in good condition or correcting body odours. 

Natural ingredients

Natural ingredients are a category that includes water, mineral ingredients and ingredients that are cultivated or farmed. In a product, these ingredients can be incorporated:

  • Raw, i.e. as harvested (water, plants, minerals, honey, wax, milk…)
  • After being extracted or physically treated: for example, pressing or crushing a seed, maceration of a plant…

The following ingredients are not of natural origin: petrochemical fractions, preservatives and denaturants of petrochemical origin.

Ingredients of natural origin

Naturally occurring ingredients refer to all ingredients that are not obtained from petroleum. They include natural ingredients that have been physically transformed (as described above), as well as natural ingredients that have been extracted or chemically processed according to the principles of green chemistry, i.e. ingredients for which a chemical reaction between several natural elements has been necessary to enable their manufacture (e.g. fermentation, saponification, etc.)

Plant origin

The ingredients of plant origin are extracted from plants: roots, leaves, fruits, seeds, tree bark, etc.

Animal origin

These are all the ingredients that make up the animal or are produced by it. They can be cartilage, collagen, milk, honey, eggs, etc.

Mineral origin

Ingredients of mineral origin are derived from rocks, sediments, sand or earth. This category includes ingredients such as zinc, iron, clay, silica, salt…

Water is also considered mineral.

Synthetic origin

Synthetic products are either chemically processed or derived from synthetic, i.e. man-made, molecules. Sometimes it is necessary to incorporate chemical ingredients into certain products until a natural alternative is found.


A vegan product/ raw material is free of all animal substances (products from breeding, slaughter, hunting and fishing). 

V. Selection criteria: Raw materials

Origin: vegetable, mineral or synthetic

All the raw materials used in Novexpert Laboratories’ products are either of vegetable, mineral or synthetic origin.


We do not use any substances of animal origin in products bearing the Vegan claim.


A product can be said not to contain GMOs when :

  • On the one hand, the raw material has not been genetically modified,
  • On the other hand, the raw material has been genetically modified, but the final ingredient does not contain any GMOs, for example as a result of a thorough purification process.

There is no specific framework that specifies or limits the use of GMOs for the cosmetics industry in Europe. The regulation on cosmetic products, Regulation (EC) No 1223/2009, does not mention the issue of GMOs and does not impose any requirements or restrictions. Therefore, specific rules and regulations for other industry sectors, notably food, may be of interest to consider.

We systematically ask our raw material suppliers for a GMO-free certificate.

No animal testing

In Europe, the ban on animal testing of finished cosmetic products has applied since 11 September 2004, while the ban on testing of ingredients or combinations has been in force since 11 March 2009.

The marketing ban applies since 11 March 2009 for all human health effects except repeated dose toxicity, reproductive toxicity and toxicokinetics.

For these specific health effects, the testing ban has been in force since 11 March 2013, regardless of the availability of alternative methods to animal testing.

We systematically ask our suppliers of raw materials for a certificate of absence of animal testing in accordance with the European regulation (EC) N° 1223/2009.

All these documents are filed in the raw material folders (Composition and Process-Origin folders) and are also filled in for each raw material on Coptis.

VI. Manufacturing and packaging

In accordance with the European regulation (EC) N° 1223/2009, Novexpert Laboratories brand products are manufactured and packaged according to Good Manufacturing Practices.

VII. Finished products

In accordance with the European regulation (EC) N° 1223/2009, Novexpert Laboratories products are not tested on animals. For each product, we have a declaration of non-animal testing attached to the assessment report on the safety for human health of the cosmetic product in question.

This report is available in the DIP file of each product, more precisely in the safety assessment file.

This declaration states that the product has not been tested on animals in accordance with Article 18, page 71, of Regulation (EC) No 1223/2009.