Cosmetic Analysis - the predecessor platform from which Transpareo emerged - has offered ingredient transparency for cosmetic products since 2008. For almost two decades. What other sectors can learn from it before they set up their own DPP process.
Why cosmetics was early
The cosmetics sector had to live with mandatory product transparency considerably earlier than others. The EU Cosmetics Regulation 1223/2009 has prescribed since July 2013 that every product package must contain a complete INCI list. That is de facto the EU’s first “analogue DPP”: a printed, standardised, complete list of constituents on the packaging.
More than a decade before the ESPR. The sector had time to make mistakes. The other sectors are making them now. Avoidably.
What cosmetics got right
INCI as a common language: the International Nomenclature of Cosmetic Ingredients is a standard that has been maintained for 30 years. “Aqua” is on every bottle, whether made in Seoul or Paris. For the DPP route the lesson is: standardise your vocabulary before you talk about data models.
Anyone setting up a textile DPP today should consider: what is my INCI? Is it EN ISO 2076 for synthetic fibres? Is it BS 8903 for an ethical supply chain? Without a common language, every technical integration is a translation project.
Order by concentration: INCI lists are sorted in descending order by concentration. A simple trick that gives end consumers real information: substances above 1 per cent are shown explicitly, those below in a collective section. That is transparency without betraying trade secrets.
Transferable to the DPP: show the main components individually, small additives in a summarised section. Nobody needs the exact quantity of every adhesive additive in a shoe.
Product liability goes to the manufacturer or the party placing on the market: Article 4 of the Cosmetics Regulation defines a “Responsible Person” - a natural or legal person in the EU who is responsible for compliance. No matter where the product was made, there is exactly one EU address for queries and liability claims.
The ESPR adopts the model. Anyone who imports products needs an EU-based responsible person. Whoever underestimates this buys, in the worst case, customs problems.
What cosmetics got wrong
Micro-ingredients in one pot: everything below 1 per cent may be named summarily (“Parfum”). That is transparent for the quantity, but opaque for the identity. An allergy sufferer who reacts to linalool does not find the molecule in the ingredient list - even though it is in the fragrance.
The lesson for other sectors: aggregates of tiny quantities create blind spots. The DPP should name tiny quantities, even if the percentage is small. Transparency is not only quantity, but also identity.
The “fragrance” gap: perfume compositions are legally summarised as one constituent (“Parfum”), even though they consist of dozens of individual molecules. More than 80 fragrance allergens must be named separately under the EU list expanded in 2023 - nothing else. A trade secret that remains a health blind spot.
The DPP must not take this route. If the material composition stays hidden, the recyclability assessment fails. The middle way: all components present in the data architecture, access tiered (public: category; authority: complete).
Traceability down to the raw material: the Cosmetics Regulation does not require traceability down to the raw-material source. The CAS entry “Palmitic Acid” does not care whether the palm kernels come from Sumatra or a sustainably certified source. This is now recognised as a gap in the cosmetics sector, but it has never been closed by law.
The ESPR closes this gap. Origin data is mandatory. Anyone planning cosmetics-style minimum transparency is planning too little.
What we learned in almost two decades
As a platform that has analysed and assessed cosmetic raw materials since 2008, we have learned a few things that are reusable for DPP projects.
Data quality is not binary. A data set is not “right” or “wrong”. It is 70 per cent complete, 80 per cent current, 50 per cent checked. Anyone who waits for perfect data before publishing a DPP never publishes. Better: data with explicit quality indicators. Then the reader knows what they can take from the value.
Translation does not scale linearly. The first 5 EU languages are work. The next 15 are a grind. Anyone who waits until the German version is perfect before starting the Dutch version has, after three years, 27 half-finished languages and zero complete ones. Parallel start, terminology database, an accepted 85-per-cent solution is the faster route.
Regulation is the beginning, not the end. The Cosmetics Regulation describes obligations. The sector’s interesting features - eco-labels, sustainability-certified product lines, ethical sourcing chains - emerged after the obligation, on its basis. The DPP should be thought of this way: obligation as a foundation, added value on top. Not the other way round.
Concrete takeaways for other sectors
If your sector is just stepping onto the ESPR path, steal three things from cosmetics:
- Establish your INCI: define now which technical language you recognise as a baseline. That saves you a translation layer per system later.
- Implement tiering: show tiny quantities aggregated, but store them individually. If in 10 years an allergen or a regulatory requirement is added, you have the data ready.
- Make origin transparent: cosmetics failed to do this and has dragged the gap along for 30 years. Close it from the start.
A retrofit in 5 years typically costs two to three times as much as a single clean set-up.