Trending cosmetic ingredients
Will your finished product still be a cosmetic?
Exosomes, PDRN, CICA and retinoid alternatives show why checking whether an ingredient can be used is only part of the regulatory assessment.
The beauty market moves quickly, and new ingredients can become commercially important long before their regulatory position feels straightforward. Trending actives such as exosomes, PDRN, retinoid alternatives and CICA can create exciting opportunities for skincare brands.
But with some of these ingredients, the key regulatory question is not simply whether the ingredient itself can be used. Businesses also need to consider whether the finished product (taking account of its intended function, mode of action, claims and presentation) still falls within the definition of a cosmetic.
That distinction matters commercially. An ingredient may be possible to formulate with, but if the benefits that make it attractive rely on a medicinal or therapeutic product story, it may not be the right choice for the product the brand wants to bring to market.
Before you formulate: start with the product you want to sell
A supplier presentation can make a new ingredient look like an obvious opportunity. But regulatory suitability is only part of the decision. Businesses should also ask whether the ingredient will allow them to create and market the product they actually have in mind.
What do you want the product to do? Which benefits does marketing want to communicate? How is the ingredient said to achieve those effects? What information and evidence can the supplier provide? And does that combination still result in a cosmetic product in the UK and EU?
Answering these questions early can avoid a much more difficult problem later. An ingredient may be suitable for use in a cosmetic formulation, but if its most commercially attractive benefits rely on claims or effects that sit outside the cosmetic framework, businesses may need to rethink the claims, the product positioning or the ingredient itself.
The examples below show how different those considerations can be depending on the ingredient.
Exosomes
Exosomes are attracting significant interest in skincare because of their association with cellular communication. However, their origin matters. In both the EU and UK, cells, tissues or products of human origin are prohibited for use in cosmetic products. Human-derived exosomes therefore present a clear regulatory barrier for cosmetics.
For exosomes from non-human sources, the position needs a more individual assessment. A plant-derived or other non-human origin does not, by itself, confirm that an ingredient is suitable for cosmetic use. Brands should understand the identity and source of the material, how it is produced, the available safety information and how it is intended to work in the finished product.
The intended product story matters too. Claims around regenerating skin, stimulating cell repair or altering gene expression may raise questions over whether the product's intended purpose and action remain cosmetic.
For a brand, the practical question is therefore not simply “can we use exosomes?”, but whether the particular material, its intended action and the product story built around it work together within the cosmetic framework.
For more information on exosomes, please refer to Bloom's ‘Exosomes’ article published on 2 September 2025.
PDRN (Polydeoxyribonucleotide)
PDRN has become increasingly popular in skincare, particularly in products positioned around rejuvenation and restoration. Where PDRN or a PDRN-type material is animal-derived, its source, composition, purity and safety information will need careful consideration as part of the product safety assessment.
Businesses should also be clear about the intended route of application. Products intended to be injected are not cosmetics, so an injectable PDRN product will fall outside the cosmetic framework. A different regulatory framework may also apply depending on the product's intended purpose and mode of action.
For topical products, businesses should assess the actual material being used rather than assuming everything marketed as “PDRN” has the same regulatory position. The formulation, safety information, intended purpose, mode of action and claims all need to be considered together.
Claims are particularly important. Statements that a product can repair damaged DNA, regenerate tissue or stimulate cellular wound healing would create significant borderline concerns and may make the product appear to have a medicinal rather than cosmetic purpose.
If those are also the benefits driving the commercial interest in the ingredient, the business may need to decide whether alternative cosmetic positioning still delivers a compelling product proposition.
Centella Asiatica
Centella Asiatica, commonly referred to as CICA, is widely associated with soothing, antioxidant and barrier-supportive benefits. Unlike some of the other examples in this article, the main regulatory question is not necessarily CICA itself, but how the finished product is positioned.
Claims focused on soothing the skin, supporting the skin barrier or improving its appearance may fit comfortably within cosmetic positioning where appropriately supported. Claims to treat inflammatory skin conditions such as eczema or rosacea, heal wounds or stimulate therapeutic tissue repair are very different and may move the product towards medicinal presentation.
This does not necessarily mean changing the ingredient. The commercial decision may instead be whether the proposed claims can be adjusted while still giving consumers a clear and compelling reason to buy the product.
Retinoid alternatives
“Retinoid alternative” is a broad marketing description rather than a single regulatory category. Ingredients positioned in this way can have very different chemistry, safety profiles and regulatory requirements, so businesses should check the exact ingredient rather than relying on the general description.
Where a formulation contains an actual retinoid or vitamin A derivative, any specific ingredient restrictions applying in the intended market must also be considered.
Claims remain important too. Claims about improving the visible appearance of lines, texture or firmness are very different from claims to treat acne or suggesting that a product provides a prescription-strength therapeutic effect. The complete claim, supporting evidence, product composition and overall presentation should therefore be assessed together.
Checking the ingredient at concept stage also prevents assumptions made by marketing or product development from carrying through into the finished product. A description such as “retinoid alternative” may be commercially useful, but it does not tell the regulatory or safety team exactly what material is being used or what evidence will be needed.
What should brands do before using a trending ingredient?
When developing cosmetic products containing new or trending ingredients, businesses should:
Understand exactly what the ingredient is. Confirm its identity, source, composition, manufacturing information and available safety data, and check its regulatory status in each intended market.
Start with the product proposition. Consider what you want the finished product to do, which benefits are commercially important and how the ingredient is said to achieve those effects. If the intended purpose or action starts to look therapeutic or medicinal, consider classification before development progresses further.
Review claims early. Do not wait until artwork is finalised. Consider claims alongside the ingredient's mode of action and supporting evidence. If the claims that made the ingredient attractive cannot reasonably be used for a cosmetic, decide whether alternative positioning is still commercially worthwhile.
Check the route of application and format. Injected products are not cosmetics. Vials, ampoules and droppers are not automatically excluded, but the instructions and presentation should make it clear that the product is for external cosmetic use and should not imply injection or other invasive use.
Consider the whole product presentation. Packaging, labelling, marketing materials, websites and social media should all be consistent with the intended cosmetic purpose and avoid creating an unintended medical or therapeutic presentation.
Check the EU and UK position separately. The two markets still share many of the same underlying cosmetic principles, but detailed ingredient requirements can diverge. A formula intended for both markets should therefore be assessed against the current requirements in each.
Make the regulatory decision early
Trending ingredients can create exciting opportunities, but they do not all present the same regulatory questions. The important point is to establish early not only whether an ingredient can be used, but whether it works within the type of product the business actually wants to sell.
Doing that at concept stage gives businesses more options. There may be time to obtain better supplier information, adjust the claims, change the product positioning or select a different ingredient before significant investment has been made in formulation, testing, packaging and artwork.
Bloom Regulatory supports businesses with ingredient and formula assessments, borderline classification, claims and wider UK and EU cosmetic compliance. If you are considering a trending ingredient, we can help you assess both the regulatory position and what it means for the product you want to bring to market. Please contact info@bloomregulatory.com.
Darshni Pattani