Colour cosmetics — foundation, lipstick, mascara, blush, pressed powder — are formulated and manufactured in New Zealand and Australia by specialist formulation studios rather than large factories. Pigments must come from the permitted colourant lists, SPF claims trigger separate rules, and indie-scale runs typically start at 100–500 units.
Most formulation advice in this region is written about skincare. Makeup gets left out — which is a problem, because colour cosmetics behave nothing like a serum: different chemistry, different regulatory schedules, different testing. Here is what actually changes when your product has colour in it.
What counts as a colour cosmetic, and why is it formulated differently?
A colour cosmetic is any product whose primary job is to deposit visible colour — foundation, concealer, tinted moisturiser, blush, bronzer, eyeshadow, mascara, eyeliner, brow products, lipstick, gloss, tints and nail polish. Three things make them different to formulate.
Dispersion, not just emulsification. A skincare cream asks you to hold oil and water together. A foundation asks you to hold oil, water and a solid pigment load together — evenly, without flocculation, for two to three years.
Many products are anhydrous. Lipsticks, pressed powders, eyeshadows and cream sticks often contain little or no water, which changes both the preservation picture and how the product is physically made.
Shade matching is a discipline of its own. Every shade is effectively its own formula. A six-shade foundation range is six formulas that must feel identical, apply identically and oxidise identically on skin — the biggest reason makeup development takes longer than a comparable skincare line.
What are the rules for pigments and colourants in New Zealand and Australia?
In New Zealand, cosmetics are regulated by the Environmental Protection Authority under the Cosmetic Products Group Standard 2020. Permitted colourants sit in Schedule 6, aligned with the European Union's colourant annex under Regulation (EC) No 1223/2009. Schedule 6 also sets where each colourant may be used — some are cleared for all cosmetics, others restricted to rinse-off, or excluded from products used near the eye or on the lips. An updated Group Standard took effect on 1 January 2026.
In Australia, cosmetic ingredients are regulated as industrial chemicals by the Australian Industrial Chemicals Introduction Scheme (AICIS). If you import or manufacture the chemicals in your product you must be registered with AICIS, on an annual cycle, and have your introductions categorised.
Two practical consequences for a founder:
- You cannot use any pigment you like. Colourants approved for food or textiles are not automatically approved for cosmetics, and one approved for a body lotion may not be permitted near the eye. This is checked at formulation stage, not at the end.
- Purity matters as much as identity. Approved colourants carry purity criteria, including limits on heavy metal impurities — which is why cosmetic-grade pigments with supplier documentation cost more than craft-grade mica.
For the wider picture, see our guides to NZ cosmetic regulations and Australian compliance under AICIS and the TGA.
Does adding SPF to a foundation make it a sunscreen?
This catches out more makeup founders than anything else. In Australia a primary sunscreen — one whose main purpose is sun protection — is a therapeutic good regulated by the TGA and must be listed on the ARTG. Tinted bases and foundations containing sunscreen at SPF 4 or above are instead treated as excluded goods under the Therapeutic Goods (Excluded Goods) Determination 2018, provided they meet the definition of a cosmetic.
The catch: exclusion from therapeutic goods regulation does not exempt you from the science. If you make an SPF claim, the product must still meet the testing and labelling requirements of the Australian/New Zealand sunscreen standard — in-vivo SPF testing on your finished formula, an external cost on a timeline of its own, and not something you can infer from your UV filter percentage. Our honest advice to early-stage brands: launch the tint first and add SPF as a version two once you have revenue. It is the most common reason a first makeup launch slips by six months.
What does colour cosmetic development actually involve?
We run makeup projects through the same five-stage Pathfinder Framework we use for skincare — discovery, route selection, R&D and stability, IP and compliance, small-scale manufacturing — with extra loops for shade work. We agree texture and finish first in a single base shade, build the range around it once that is signed off, then run stability and compatibility on the extremes: usually the lightest and deepest shades, which carry the lowest and highest pigment loads.
Most makeup projects run through The Visionary (9–12 months, starting from $4,000, with full IP transferred to you), because shade ranges need the iterations. A single-shade product — a lip balm, a universal tint, a cream blush — can often go through The Accelerator in 4–6 months, starting from $2,000.
What are realistic MOQs and timelines for an indie makeup brand?
Our minimum order quantities sit between 100 and 500 units. For a makeup brand, read that per shade, not per product — a five-shade lipstick range at 200 units each is a 1,000-unit first order. That is the number that decides whether a range is viable, and it is worth modelling before you fall in love with a twelve-shade concept. Our advice: launch narrow. Three shades done properly beat twelve done thinly, and they let you learn which shades actually sell before you commit capital to the rest.
What testing does a colour cosmetic need before launch?
Stability testing applies to every product — typically 12 weeks accelerated, checking for colour drift, pigment settling, syneresis in creams and cracking in pressed powders. Colour drift is the one thing skincare brands never think about and makeup brands cannot ignore.
Preservative efficacy testing (ISO 11930 challenge testing, NZ$1,200 per formula) applies to water-containing products — liquid foundations, tinted moisturisers, cream blushes, mascara. Genuinely anhydrous products such as lipsticks, pressed powders and eyeshadows are assessed differently, which is a real cost saving on a powder-led range.
Packaging compatibility testing matters more in makeup than in skincare: pigments and their carrier oils can leach into or stain component plastics, and a foundation pump has to move a far more viscous product than a serum pump. Test the formula in the actual component, not a generic jar.
Frequently asked questions
Can you formulate makeup in New Zealand for an Australian brand?
Yes. We are based in Auckland and work with brands across New Zealand and Australia. Formulation, stability, compliance documentation and small-batch manufacturing all happen here, with documentation prepared for NZ, AU, EU and US markets.
Do I own the formula for my shade range?
Through The Visionary, yes — full IP transfer to you before manufacturing, including every shade in the range. Through The Accelerator, IP is shared and you own the finished SKU.
Can you make vegan and cruelty-free makeup?
Yes. We are a cruelty-free studio and formulate vegan ranges as standard. The ingredients to watch in colour cosmetics are carmine (an insect-derived red), beeswax and lanolin in lipsticks and balms, and silk or keratin in mascaras. All have workable vegan alternatives, though replacing carmine in deep reds takes iteration.
Can you match a shade from a product I already sell?
Usually yes, if you can supply a retained sample and the original specification — matching from a photograph or shade name alone is not reliable. Book Ask The Chemist ($150, 30 minutes) and bring the sample; we will tell you honestly whether it is matchable before you commit to a project.
Where to start
The cheapest hour you will spend on a makeup range is the one before you commit to a shade count. Start with our services overview to see which pathway fits, or get in touch with your concept and target price point — we will tell you what is realistic, including when the honest answer is to start smaller.
