So, your indie brand is the darling of the top Stateside influencers and all the positive attention means your DMs are full of requests from shoppers as far afield as Europe and Asia – all wanting to know when they too can get their hands on your latest glow-givers and lipsticks. This means it’s time to think about exporting.
This, the next in our series of articles for indie brands, looks at branching into new markets and what you need to consider before taking the leap.
For years the industry has discussed global regulatory harmony, but the truth is, it’s almost certainly some way into the future, and it may not be possible at all.
However, despite some hurdles, there are plenty of advantages of being a US-made brand when it comes to selling abroad. American-made products are generally considered to be safe and of high-quality, and US companies have a general reputation for being honest and ethical in their business dealings.
But, before you begin to contact retail buyers and distributors outside of the US there are a number of things to consider. Not least, are you really ready to export and have you done your research on country-specific regulations?
The first step is to carefully consider which new territories you’d like to sell into and the likely demand for your brand. Remember that exporting success rests not only on how good your brand/product is, but also your understanding of any unique characteristics in each target market.
What if you need to modify your products to comply with local regulations – this will not only apply to the product itself but its packaging, labelling and any cultural nuances that could render your brand unsellable if you get it wrong. You will also need to file the correct paperwork, with the correct authorities before your first pallet has even made it into the shipping depot.
To begin your export journey, we recommend that one of your first ports of call is the Food & Drug Administration website. It includes Frequently Asked Questions (FAQs) and information for domestic brands wanting to broaden their horizons to new territories, plus products that will be produced or packaged specifically for foreign markets.
It also offers guidance on certification. For instance, some countries insist on a Cosmetics Export Certificate, while others may require a Certificate of Free Sale guaranteeing that products intended for export comply with all relevant US regulations and are available for sale within the country.
The FDA won’t issue a Certificate of Free Sale, but some individual states or trade organisations, such as the Personal Care Products Council, do. This 125-year-old organisation is the leading, national trade association representing cosmetic and personal care companies in the US. It serves as a resource, advising on scientific, legal, regulatory, legislative and international issues for the $488 billion global industry.
It is also home to the International Regulatory Database – a comprehensive compilation of global regulations for cosmetics and personal care products in more than 60 countries. While it’s only available to PCPC members, subscribers will find most information they need, from rules on cosmetic regulations, packaging, environmental and advertising codes, plus product labelling, registration and regional industry guidelines. There is also an ingredients database that allows members to compare regulatory information country-by-country.
Sunscreens and animal testing are two pertinent examples of how different territories apply different codes.
In the EU, sunscreens are classed as cosmetic. However, in the US and Canada sunscreens are considered to be OTC drugs. This means they are subject to greater regulation. At the same time Canada has an additional classification for sunscreen products with physical UV filers. They are classed as ‘Natural Health Products’ and require a natural product number. In China, sunscreens are catergorized as “special use cosmetics”, requiring pre-market registration with the National Medical Product Administration, which includes obligatory testing at accredited labs in the country. Each territory has individual labelling requirements, making it imperative for any brand wanting to sell in those markets to adhere to local rules.Attitudes to animals testing also differ from region to region. In Europe, the EU Cosmetics Regulation prohibits the testing of finished cosmetics products and ingredients on animals, as well as the marketing of finished cosmetics products and ingredients, that were tested on animals.
However, in China, until very recently animal testing has been a controversial requirement of selling there. Earlier this year the Gansu Province National Medical Products Association announced that post-market testing for finished, imported and domestically produced cosmetic products, would no longer be required. However, it still insists on pre-market testing at the moment.There is so much to read, digest and understand before any brand embarks on an export strategy. So we strongly advise using the links we’ve supplied as a starting point for research and understanding what steps to take and building from there.
Here are a few more resources to help you on that journey:
- Exporting to Europe: https://www.export.gov/article?id=Steps-for-Success-Exporting-Cosmetics-to-the-European-Union and https://www.ctpa.org.uk/supplying-or-manufacturing-a-cosmetic-product
- Exporting to Brazil: https://www.export.gov/article?id=Brazil-Import-Requirements-and-Documentation
- Exporting to the ASEAN territories: https://aseancosmetics.org/
- Exporting to China: https://msc.ul.com/en/resources/article/china-compliance-cosmetic-products/
Exporting products can be highly beneficial for businesses, and with the right research, knowledge and patience – you’re brand could be the next international success. Good luck!
And don’t forget, you can register to attend in-cosmetics North America by visiting the event website: northamerica.in-cosmetics.com/register