Baby and children's skincare has to be formulated to a stricter safety standard than adult skincare. Children under three have thinner, more permeable skin and a much higher surface-area-to-body-weight ratio, so the same ingredient at the same concentration delivers a far larger relative dose. That single fact changes your preservative system, your fragrance decision, your actives, and the safety assessment behind the product.
Baby care is commercially attractive for an indie founder in New Zealand and Australia — parents buy repeatedly and stay loyal. It is also the category where a formulation shortcut is least forgivable. Here is what actually changes when you brief a chemist for a baby or children's range.
What makes baby skincare formulation different from adult skincare?
A child is not a small adult. Three physiological differences drive every formulation decision:
- Skin barrier maturity. A newborn's stratum corneum is thinner and still developing for roughly the first year, so penetration of small molecules is higher.
- Surface area to body weight. An infant has proportionally far more skin per kilogram than an adult. Systemic exposure from a whole-body lotion is therefore much higher per kilo of body weight.
- Exposure pattern. Hand-to-mouth contact, time spent in a nappy under occlusion, and the fact that a carer applies the product mean real-world usage looks nothing like an adult serum.
The EU's SCCS Notes of Guidance — which underpins the ingredient schedules used in both New Zealand and Australia — publishes separate exposure factors by age: body weights, surface areas and product quantities for infants rather than adults. A competent safety assessment uses those figures, not adult defaults, and expects a higher margin of safety.
Which ingredients are restricted in products for children under 3?
Both markets take their restricted-ingredient lists from the EU Cosmetic Regulation (EC) No 1223/2009 annexes, and several of those entries carry an explicit under-three restriction. Two common examples:
- Salicylic acid — not to be used in products for children under three years of age. The restriction was broadened after the SCCS reviewed it as an eye irritant, so it now covers all products for that age group.
- Iodopropynyl butylcarbamate (IPBC) — not to be used in products for children under three, except in bath products, shower gels and shampoos. The restriction exists because of iodine bioavailability.
Beyond the hard restrictions sit the judgement calls: avoiding fragrance allergens entirely, choosing a preservative with a strong safety profile rather than the cheapest effective one, keeping the ingredient list short, and skipping essential oils that would be perfectly acceptable in an adult product. "Natural" is not a safety argument here — a botanical extract can be a sensitiser, and a well-chosen synthetic preservative is often the safer choice for an infant.
Is my baby product a cosmetic or a therapeutic good in Australia?
This is where most baby ranges get into trouble, and the answer turns on your claims and your ingredients — not on what you call the product.
In Australia, cosmetic ingredients are regulated as industrial chemicals under the Industrial Chemicals Act 2019, administered by AICIS, which does not regulate therapeutic goods. A nappy balm that claims to moisturise or form a barrier sits comfortably as a cosmetic. The moment it claims to treat or heal nappy rash, or contains a pharmacologically active ingredient above the relevant threshold, it becomes a therapeutic good under the Therapeutic Goods Act 1989 — meaning TGA evaluation, an AUST L or AUST R number, and manufacture under cGMP. That is a different business entirely.
So your marketing copy has to be written alongside the formula, not after it. We cover the wider picture in our guide to cosmetic compliance for Australian brands.
What does New Zealand require for a baby skincare range?
New Zealand regulates cosmetics through the EPA's Cosmetic Products Group Standard 2020 (HSR002552) under the HSNO Act. Schedules 4 to 8 of that standard are based on the EU Cosmetic Regulation annexes, so the under-three restrictions above apply here too. You also need compliant ingredient labelling in INCI, and you must hold the technical information that supports your product's safety.
Therapeutic claims in New Zealand pull a product under the Medicines Act 1981, and unsubstantiated marketing claims are a Fair Trading Act issue for the Commerce Commission. Our guides to cosmetic labelling requirements and what you can legally claim on a skincare label go deeper on both.
What testing does a baby product need?
The testing set is the same as any cosmetic, but the tolerance for failure is lower:
- Preservative efficacy (challenge) testing to ISO 11930 — essential. A baby lotion used by wet hands over months is a real contamination risk. We run this at NZ$1,200 per formula. See our preservative efficacy testing guide.
- Accelerated stability testing — typically 12 weeks, to confirm the formula and the pack survive the shelf life you intend to print.
- Packaging compatibility — particularly relevant for oils and balms.
- Microbiological testing on the production batch.
Many founders also commission human patch testing or paediatric dermatologist review to support sensitive-skin positioning. Optional, but it is what separates a credible baby brand from an optimistic one.
How long does it take, and what does it cost?
At The INCI Lab we develop baby and children's formulations through two pathways. The Accelerator adapts a proven base to your brief in roughly 4–6 months, starting from NZ$2,000. The Visionary develops a bespoke formula from scratch over 9–12 months, starting from NZ$4,000, with full IP transferred to you before manufacturing. Minimum order quantities run from 100 to 500 units depending on the product and pack, so you can launch a baby range without committing to a pallet of stock.
If you are still deciding whether a baby line is viable, Ask The Chemist is a 30-minute consult at NZ$150 — usually enough to establish whether your product idea sits on the cosmetic side of the line before you spend anything else.
Frequently asked questions
Can I use essential oils in a baby product?
Technically yes, within the restricted-substance limits, but we generally advise against it for children under three. Essential oils are a leading source of fragrance allergens, and the safety margin available in an infant product is much narrower than in an adult one. Fragrance-free is the safer commercial and formulation position.
Do I need a different formula for New Zealand and Australia?
Usually no. Both markets draw their restricted-ingredient schedules from the EU annexes, so a single compliant formula generally serves both. Labelling and claims are where the two diverge, and that is handled at artwork stage rather than in the beaker.
Can I say my baby cream treats eczema or nappy rash?
No — not as a cosmetic. Treatment claims for a named skin condition make the product a therapeutic good in Australia and a medicine in New Zealand. Barrier, soothing and moisturising claims, properly substantiated, are the cosmetic equivalent.
Is "natural" or "organic" safer for babies?
Not automatically. Certification speaks to sourcing and processing, not to infant safety. A short, well-preserved, allergen-free formula is what matters. Organic certification is entirely achievable alongside that — see organic cosmetic manufacturing in NZ and Australia.
What is the minimum order quantity for a baby skincare range?
Between 100 and 500 units per SKU with us, depending on the format and packaging. That is deliberately low so first-time founders can test a range of two or three products rather than betting everything on one.
Can you formulate baby wipes or bath products too?
Yes. Bath washes, hair and body cleansers, balms, lotions and oils all sit within our capability. Wipes involve a substrate supplier as well as a formulation, so we would scope that through a discovery call.
Thinking about a baby or children's range? We are an award-winning, cruelty-free formulation studio in Auckland working with indie brands across New Zealand and Australia. Explore our formulation pathways or book a discovery call.
