The waiver, in plain terms
Certain solid formulations no longer require the full data submission package that would previously have preceded market entry. The stated aim is to stop documentation volume from being the bottleneck on formats that are, chemically, often simpler than the liquids they replace.
What the waiver does not do is transfer risk. The manufacturer still holds the safety file; the regulator has simply stopped asking to see all of it before launch. For a brand, that’s a timing benefit and an accountability shift in the same sentence, and the second half is the one that tends to get lost in the sourcing conversation.
It also arrives alongside a tighter general framework — the Cosmetics Act in force from January 1, 2025 raised the legal and consumer-facing exposure for companies putting products on shelf. The two moves are not contradictory. Less paperwork ahead of launch, more consequence afterwards.
Microbial safety is the part that stays hard
The received wisdom about waterless products is that they can’t support microbial growth, so preservation is a solved problem. That holds while the product is dry. It stops holding at the moment of use.
Rehydration is the real test condition
A shampoo bar sits in a wet shower. A cleansing bar is handled with wet hands and left on a dish. A powder cleanser meets water in a palm. Each of those is a rehydration event, repeated daily over the life of the product, and standard challenge testing designed for a sealed liquid in a pump bottle does not simulate it. The gap is widest for anything that intentionally contains live cultures — the probiotic skincare category, where a preservative system strong enough to guarantee safety is also strong enough to defeat the product’s premise.
In-store and made-to-order manufacturing adds a third variable, because the environmental controls of a retail counter are not those of a filling line. Any brand pursuing that model should assume its risk assessment needs to be built rather than borrowed.
Why the cost case is genuinely good
Solid cosmetics are cheaper to make and cheaper to move, and the reasons are structural rather than promotional:
- No water phase, so no water cost, and a much smaller preservative requirement.
- Lower shipped weight and volume per use, which changes freight economics on every unit.
- Simpler primary packaging — often paper or card instead of a pump, a bottle and a cap, which are three separate tooling and supply lines.
- Better ambient stability, so less loss in transit and warehousing in hot markets.
Those savings are real, but they show up against a higher formulation cost. Structuring a bar that lathers properly, doesn’t crack, doesn’t turn to mush on a wet dish, and still delivers the sensory experience of a liquid takes development time. The natural waxes and butters that hold the structure also carry the moisturising performance, and balancing those two jobs in one matrix is the actual engineering problem in this category.
The claim that solid formats match liquid performance across the board should be treated with some care. Rinse-off cleansing translates well. Foundations and colour products are harder, and spreadability remains the honest weak point where a brief asks for a solid version of something that has always been an emulsion.
Where the demand is coming from
Zero-waste buyers built this category and no longer define it. Two other segments are moving faster.
Male grooming is one. Bar-format shampoos, body washes and shaving bars remove the packaging conversation entirely and sell on convenience — a smaller kit, nothing to leak in a bag. The category has historically been under-served, and solid formats give a brand a way in that doesn’t require competing on fragrance heritage.
The second is travel and climate. In markets across Asia and Africa where heat, humidity and distribution distance all work against liquid products, a stable bar has practical advantages that have nothing to do with environmental positioning. Formulating for those markets means local skin-type work — lower-irritation systems for sensitive Asian skin profiles, differently structured matrices for high ambient temperatures — rather than shipping a European bar and hoping.
Plant-derived ingredients dominate the shopper-facing story here. Aloe, green tea and shea butter appear in most briefs, partly on performance grounds and substantially because the format has been sold as a natural choice and the ingredient list has to agree with the pack.
The compliance work the waiver doesn’t remove
Anything shipping across borders still meets whatever the destination market asks. Ingredient-level restrictions continue to tighten independently of format, and regional ingredient rules are the more common cause of a delayed launch than submission volume ever was. Relief in one jurisdiction is not portable.
Internally, the sensible response to a lighter pre-market requirement is a heavier internal one: real-use stability protocols that include repeated wetting, defined preservative-efficacy criteria for rehydrated conditions, and quality checks placed early enough in development to change the formula rather than late enough to only document it.
The last gap is the consumer. Regulation has moved ahead of familiarity here, as it did with liquid-to-solid lip formats. Outside committed zero-waste audiences, a shopper still trusts a bottle more than a bar, and no amount of faster market entry fixes that. Packaging and in-store messaging are carrying that job, and for most brands entering the format it is a larger workload than the compliance file ever was.
“What stands out to us on the marketing side isn’t just the waiver itself, but how quickly brand partners have started asking for solid-format options once they hear the words ‘faster to market.’ In client conversations, solid cosmetics used to be pitched purely as a sustainability story — now buyers are asking about it as a speed-to-shelf story too, which changes how we help brands position the format to retailers. The honest caveat we give clients is that consumer education still lags behind the regulation: shoppers outside core zero-waste audiences don’t yet reflexively trust a solid cleanser or moisturizer the way they trust a bottle, so the packaging and in-store messaging still have real work to do.” — Hyejin Cho, Digital Marketing Specialist, Marketing and Communication Team at SPSCOS