The Standard · How it works
The standard,in the open.
We check a product against one clear, published standard: what's in it, how it's made, how it's tested, what's on the label, and every claim it makes. This page shows exactly what we look at, how we decide, and where each rule comes from.
The Clean Sheet is a voluntary private certification scheme for beauty and personal care. It is not currently accredited, and it does not replace regulatory approval, legal compliance obligations or professional medical advice.
The Clean Sheet is an independent private certification scheme being designed in alignment with ISO/IEC 17065 and ISO/IEC 17067. It is not currently accredited.
20
Core gates
10
Product modules
30
Claim modules
47
Standards referenced
What The Clean Sheet certifies.
That one specific product, a named SKU and variant, meets a published standard written for that kind of product.
In the markets the brand declares, against the law and evidence rules of each of those markets.
Based on the confidential dossier: quantitative formula, safety assessment, test reports, manufacturing records and claims evidence.
With an independent certification decision, and a live public proof page listing exactly what was verified.
What certification does not mean.
It is not a guarantee that no individual will ever experience irritation or an allergic reaction.
It is not regulatory approval, and never substitutes for legal registration or notification.
It does not cover products, variants or claims outside the certified scope.
It is not a blanket “safe” or “clean” verdict. It only covers the specific things listed on the proof page.
How the standard is applied
One product. One stack of rules.
Every product goes through the same six steps. Keeping them separate means a rule written for sunscreen never gets misapplied to a face wash.
01
Twenty mandatory core gates
Applied to every product, in every category and market.
02
The applicable product module
Sunscreen, leave-on, rinse-off, hair, colour and other category rules.
03
Population & format overlays
Baby and child, eye, lip, intimate, aerosol, powder. Added on top based on how the product is used.
04
Relevant claim modules
Exact evidence rules for every voluntary marketing claim made.
05
Declared market requirements
India first, then EU, US, Australia, Canada, UK and ASEAN as declared.
06
Optional environmental verification
The Sustainability Evidence Code, applied only to claims actually made.
The rule that holds it all together: every safety, legal, quality and claim check has to pass on its own. Doing well on one can never make up for failing another.
Core requirements
Twenty gates. All must pass.
These checks apply to every product, whatever it is. For each one, you can see what we look at, when it applies, how we decide, and the standard behind it.
Legal status & market classification
Is the product lawfully what it says it is, in every market it is sold?
Product & market classification
Checks: That the product sits in the right legal category (cosmetic, drug, therapeutic good, medical device, biocide, food or AYUSH) and holds every registration or licence it needs.
Decision: Correct classification and all required permissions must be in place before review. The Clean Sheet never substitutes for regulatory approval.
Reference · India Cosmetics Rules 2020 plus each target-market rule.
Complete formula & ingredient legality
Checks: That every ingredient, impurity and intended use is legal in each declared market.
Decision: Every ingredient, impurity and intended use complies in each declared market.
Reference · Target-market annexes and schedules; live regulatory register.
Formula & finished-product safety
Is the finished product safe for the people who will actually use it?
Finished-product safety assessment
Checks: A signed safety assessment of the finished product, covering exposure, toxicology, effects on skin, impurities, ingredient interactions, who uses it and likely misuse.
Decision: The assessor concludes the product is safe for intended and reasonably foreseeable use. Open data gaps are closed, or the product is not certified.
Reference · SCCS Notes of Guidance, current revision.
Impurity & contaminant control
Checks: That impurities and contaminants are identified and controlled by real risk, not a blanket rule.
Decision: Limits are substance-specific and exposure-based. There is no universal 0.01% threshold.
Reference · Risk-based toxicological limits and applicable law.
Microbiological quality
Checks: That microbial limits and specified organisms are within acceptable limits.
Decision: Meets applicable limits and absence criteria.
Reference · ISO 17516:2014 and related methods (replacement edition tracked).
Preservation effectiveness
Checks: That the product resists microbial contamination in its actual package and use.
Decision: Passes the chosen acceptance criteria, or has a robust low-risk justification. Jars and high-contact formats receive extra scrutiny.
Reference · ISO 11930:2019 + Amd 1:2022; ISO 29621:2017.
Local tolerance strategy
Checks: That skin, eye and related tolerance is addressed proportionally to exposure and uncertainty.
Decision: The method must match the endpoint, formulation domain and decision context. Medical-device ISO 10993 methods are not default cosmetic methods.
Reference · OECD TG 439, 442C/D/E, 492/492B, 432/498 where applicable.
Population & exposure overlay
Checks: That safety is assessed for the specific population marketed to.
Decision: The safety conclusion covers the marketed population. No arbitrary universal 10× margin is used.
Reference · SCCS current guidance and applicable law.
Nanomaterial & particle assessment
Checks: That nanoforms and inhalable particles are identified, permitted and safety-assessed.
Decision: The exact form and route are legally permitted and assessed. Spray and powder inhalation are assessed separately from dermal use.
Reference · Applicable cosmetic annexes and inhalation assessment.
Manufacturing quality & traceability
Was it made properly, and can each batch be traced?
Cosmetic GMP
Checks: That the manufacturing site operates a functioning Good Manufacturing Practice system.
Decision: The GMP system operates effectively. ISO 22716 does not prove product sustainability.
Reference · ISO 22716:2007 and applicable law.
Batch identity & release
Checks: That every commercial batch is traceable and meets its specifications.
Decision: Each commercial batch is traceable and meets justified specifications.
Reference · ISO 22716:2007.
Stability programme
Checks: That shelf life and period-after-opening are supported by real data.
Decision: Shelf life and PAO are supported. ISO/TR 18811 does not prescribe one universal protocol.
Reference · ISO/TR 18811:2018 as guidance.
Packaging compatibility
Checks: That the package protects the formula through shelf life and use without unsafe interaction.
Decision: The package protects the formula through shelf life and use without unsafe interaction.
Reference · Risk-based protocol; applicable packaging law.
Label & consumer information
Checks: That all mandatory label information is present, legible and accurate.
Decision: All mandatory information is legible, accurate and consistent with the dossier.
Reference · ISO 22715:2006 plus applicable law.
Supplier & change control
Checks: That changes to formula, supplier, process, package, claim, population or market trigger review.
Decision: Any real change triggers a fresh review. Certification is not carried over automatically.
Reference · ISO 22716:2007.
Claims & consumer information
Does every claim, on every channel, match the evidence?
Claim-to-evidence matrix
Checks: That every material claim is truthful, relevant, understandable and supported at finished-product level.
Decision: Each material claim is truthful and supported at finished-product level where the claim is about the product. Unsupported claims are corrected or removed before certification.
Reference · EU 655/2013; India Rule 36; ASCI and consumer law.
Digital & physical label parity
Checks: That no channel makes a stronger or different claim than the reviewed dossier.
Decision: No channel makes a stronger or different claim than the reviewed dossier.
Reference · India Rule 36 and target-market advertising law.
Evidence provenance & certification governance
Is the evidence sound, and the decision independent and maintained?
Post-market surveillance
Checks: That an active system catches complaints and adverse events after certification.
Decision: The system is active and trends are reviewed. Serious risks can suspend certification immediately.
Reference · India and target-market reporting duties; MoCRA where applicable.
Evidence provenance & laboratory competence
Checks: That critical tests come from competent laboratories within their accredited scope.
Decision: Critical tests use competent laboratories within scope. Brand summaries alone are insufficient.
Reference · ISO/IEC 17025:2017 for laboratory competence.
Certification decision & surveillance
Checks: That an independent decision is made, scoped, time-limited and kept under surveillance.
Decision: All applicable gates pass. Weighted points cannot compensate for a failed legal, safety, quality or material-claim gate.
Reference · ISO/IEC 17065:2012 and ISO/IEC 17067:2013.
Product standards
Rules built for each product.
On top of the core checks, each kind of product has its own rules. Our launch modules are active now. Others are marked clearly as coming later.
Sunscreen & SPF products
Primary sunscreen, SPF moisturiser, tinted sunscreen, lip SPF, stick, spray
Risk · Highest
Leave-on skincare
Serum, moisturiser, toner, mask, facial oil, eye cream, body lotion
Risk · High
Rinse-off skin & body
Face cleanser, body wash, scrub, rinse-off mask, hand wash
Risk · Medium
Baby & child
Baby lotion, wash, shampoo, diaper cream, powder, child sunscreen
Risk · Highest
Hair & scalp
Shampoo, conditioner, hair oil, serum, mask, scalp treatment, colour, smoothing
Risk · High
Colour cosmetics
Foundation, lipstick, balm, mascara, kajal, eye shadow, blush, powder
Risk · High
Deodorant, antiperspirant & aerosol
Roll-on, stick, cream, aerosol deodorant, antiperspirant
Risk · High
Intimate external-use products
External wash, wipe, deodorising product
Risk · Highest
Nail products
Polish, remover, gel, adhesive, treatment
Risk · Highest
Oral care
Toothpaste, mouthwash, whitening
Risk · Highest
Explore the evidence.
Two of the most useful parts are open to anyone: the exact proof every marketing claim needs, and the full list of standards we rely on.
For brands
Certification assesses your product against this standard, with an independent decision and a public proof page. It is voluntary and independent, and it is not a regulatory approval.
Apply for certification