Frequently Asked Questions About Private Label Cosmetic Manufacturing
What is a Cosmetic Product?
According to Article 2 of the Turkish Cosmetics Law No. 5324, a cosmetic product is defined as a preparation or substance intended to be applied to external parts of the human body — including the epidermis, hair, nails, lips, external genital organs — as well as teeth and oral mucosa, with the primary purpose of cleansing, perfuming, changing appearance, correcting body odours, protecting or keeping these areas in good condition.
How is it Determined Whether a Product is Classified as a Cosmetic?
Whether a product falls within the scope of cosmetics is determined by evaluating multiple factors together in relation to relevant legislation and product category requirements:
- Product composition
- Intended use and functional purpose
- Method and area of application
- Presentation and product claims
- Mechanism of action
- Marketing positioning and usage context
What is the ÜTS (Product Tracking System)?
The Product Tracking System (ÜTS) is a national digital platform used to track all medical devices and cosmetic products manufactured in or imported into Türkiye — from the production line to the final point of sale and end user.
Under Law No. 5324, cosmetic products must be notified to the Ministry via the ÜTS platform before being placed on the market in order to ensure supply-chain traceability.
Is it Mandatory to Upload “Free-From” Claims to the ÜTS System?
Yes. If a cosmetic product claims to be “free from” a specific ingredient, an accredited laboratory analysis report must be submitted.
The report must comply with TSE ISO IEC 17025 standards and confirm that the relevant substance(s) are not present in the formulation.
Manufacturers who do not submit proof are not permitted to use “free-from” claims.
What is the Difference Between “Natural Cosmetics” and “Organic Cosmetics”?
-
Natural Cosmetic:
A cosmetic product that meets internationally recognized natural cosmetic standards, but is not required to be certified as organic. -
Organic Cosmetic:
A finished cosmetic product that meets internationally accepted organic cosmetic certification requirements.
Manufacturers must hold valid certification documents to use “natural” or “organic” statements — including wording, visuals or implied claims — on labels, packaging or marketing materials.
Which Parabens Must Be Tested for “Paraben-Free” Claims?
According to the Guideline on Cosmetic Product Claims, a TSE ISO IEC 17025 accredited laboratory report must verify that the product does not contain the relevant parabens listed below:
- Methylparaben
- Ethylparaben
- Propylparaben
- Butylparaben
- Hexamidine paraben
When is a Barcode Change Required in Cosmetic Product Notifications?
Whether a barcode change is required depends on the type of revision made to the product:
- No barcode change — for minor revisions that do not affect product classification (e.g., preservative change, supplier-based raw material change)
- Barcode change required — when the brand name changes
- Barcode change required — when the product quantity/volume changes
- No barcode change — when only the product name variation changes (Lavender Soap → Lavender-Scented Soap)
- Formula revision — evaluated according to degree of change
- Claim revision — evaluated according to change in product function
Examples:
Lavender Soap → Moisturizing Lavender Soap = Barcode does not change
Anti-aging Cream → Sunscreen Cream = Barcode changes