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On the CosmoFactory podcast, discover the latest innovations along the cosmetics and personal care supply chain. Hear thought-provoking conversations with top beauty industry experts from around the world. Learn about next-level solutions and find inspiration to turn your own ideas into industry-changing innovations.
A PRODUCTION OF Cosmoprof Worldwide Bologna
CosmoFactory is the first podcast from Cosmoprof Worldwide Bologna—the most important beauty trade show in the world. Dedicated to all sectors of the industry, Cosmoprof Worldwide Bologna welcomes over 250,000 visitors from 150 countries and regions and nearly 3,000 exhibitors to Bologna, Italy, each year. It’s where our diverse and international industry comes together to build business relationships and to discover the best brands and newest innovations across consumer beauty, professional beauty, and the entire supply chain. The trade show includes a robust program of exclusive educational content, featuring executives and key opinion leaders from every sector of the cosmetics, fragrance, and personal care industry. Cosmoprof Worldwide Bologna is the most important event of the Cosmoprof international network, with exhibitions in Asia (Hong Kong), the US (Las Vegas and Miami), India (Mumbai) and Thailand (Bangkok). Thanks to its global exhibitions Cosmoprof connects a community of more than 500,000 beauty stakeholders and 10,000 companies from 190 countries and regions. Learn more today at Cosmoprof.com
CosmoFactory was co-developed in collaboration with supply-side expert Deanna Utroske, Host of the CosmoFactory podcast and Editor of the Beauty Insights newsletter.
Deanna: [00:00:00] This episode is about cosmetic and fragrance industry regulations. It's about country-specific laws and the realities of global compliance. It's about smart strategies for responding to regulatory change, and it's about the brand expansion potential and commercial advantages that come with legal compliance.
For this episode, Deepa Sinah, co-founder and technical director at GCRS has joined me in the CosmoFactory recording booth on the show floor at [00:01:00] CosmoPack. Deepa, welcome to Cosmo Factory.
Deepa : Thank you so much. Thank you so much for inviting me.
Deanna: Yeah. I'm glad you're here. GCRS, this is the company you lead.
This is an initialism for global compliance and regulatory services. I understand that, um, what your company does, and you'll correct me if I don't have it right, but you support small and mid-size brands primarily. But will you tell us more about the company, maybe where your headquarters are, a little bit more about your business specialty?
Deepa : Yes. Hi. So my company headquartered is in UK Cardiff, and our company is a regulatory consultancy supporting multinational beauty brands, manufacturer, and portfolio groups with structured international compliance. We align product safety, claims, market entry approval, coordinated global framework that protects brand equity and enables confident expansion.
So we help brands to enter the market, measure up to their co- [00:02:00] compliance, their regulatory guidelines. We provide responsible person services, and especially in Europe, you require safety assessment for every product that services we provide. We are also, our presence is also in US, GCC, India, Australia. So our clients, we help them to expand not just one single market, but expand globally at the same time.
Deanna: Wonderful. No, thank you so much for that. And I, you know, I, I think one of the, the interesting pieces of this conversation, at least I'm, I'm hoping one of the interesting pieces of this conversation will be this idea of brand growth. And I know f- through my work that, um, it's not unusual for a brand experiencing growth, maybe unexpectedly, um, particularly through maybe a viral media moment, comes upon challenges like, um, readiness in terms of manufacturing capacity- Yes.
um, you know, enough packaging available, warehouse space and fulfillment. But from what you've told me, um, before we started recording, [00:03:00] regulatory readiness is also something that brands can establish proactively. Will you, will you talk about that scenario?
Deepa : Yes, yes. So a lot of time we have seen like founders or like, you know, the whole brand, they focus, suppose they have a focus brand, they focus on send, they foc- focus on packaging, they focus on manufacturing, and that is understandable.
That is important, but you cannot leave compliance for the end. Compliance, treat compliance as your part of growth strategy. Compliance helps you to expand immediately. I just met a brand and they have a distributor ready. They have a buyer ready. Now they want me to register their product as soon as possible.
So all like, you know, how fast they can enter a market depends a lot on how regulatory ready you are for that market. So we at GCRS, we help the brand right from the ideation stage that they are globally compliant. They just have to do some final treating final licensing work before they are launching the market.
So distributors, [00:04:00] buyers are also ready. They are also ready to enter the market. So yes, I think you must understand that compliance should be part of your growth strategy.
Deanna: Yeah.
Deepa : Not something to deal at the end.
Deanna: Yeah, no, that makes very good sense. And I'm, I'm wondering if you can give us a sense, I'm, I'm sure there are, um, uh, a lot of different scenarios here, but is there a general timeframe?
If a brand knows they want to go into a new market, how soon should they be looking at compliance for that market?
Deepa : Well, ideally, uh, right from the beginning. Yeah. I really write when they are like, you know, doing a new product development when the formulation is like, you know, when they are creating the formulation right from the formulation stage, a lot of our clients, when they create a formula, they just send a copy of a formula to us that, can, can your team check all the ingredients are compliant for this market or not?
Is there any ingredient that is prohibited that is restricted? So we just then and there, we just reformulate the product because once the product is formulated, it's gone for the [00:05:00] stability, it's gone for other testing, packaging is done. And then again, reformulating the product because suppose you are a brand from GCC launching in Europe, but there are some ingredients which is not allowed in Europe.
Again, you're reformulating, you're again doing all the testing. So I believe right from the beginning, beginning, you should involve your compliance partner. You should ensure that all the raw materials used are also allowed in the market.
Deanna: Yeah.
Deepa : And compliance is needed like in the whole life cycle of the product from packaging, from, uh, licensing, safety report, testing at every stage, but yes, the sooner, the better.
Deanna: Mm-hmm. Mm-hmm. Of course. And as, as your remarks have already suggested, we know that region to region, country to country in the US, even from state to state, cosmetic regulations vary, and you know as well as I do, there are numerous industry organizations working very hard to ensure cooperation and, and aspiring to harmonized regulations globally, but today, this harmony [00:06:00] does not exist.
Um, and, and you've suggested the idea of, of being globally compliant, which makes very good sense, right? Why reformulate for each market and, and certainly the multinationals have this down, um, but some of the, the smaller and mid-size brands need more support. Talk about how you do support your customer partners in becoming globally compliant.
You, you spoke about reformulation, but I'm guessing there are marketing and product claims, there are labeling pieces. It, help me think about all the components here.
Deepa : So yes, maybe I can explain you with an example. Suppose one of my clients, they have a skincare product. So Europe is one of the strictest market, even in U- US California.
Yes, yes. California has one of the stricted regulation. It's almost as part of the European regulation. So if we have a little conservative approach when it comes to safety of the ingredients, transparency of the ingredients, because the consumers today are very savvy. They want to know everything about their ingredient, as well as the regulations here are very strict.
So we take a little [00:07:00] conservatives approach when they are, when they have the vision to launch their product ultimately globally, and this happens because of the social media. Your product goes so viral so quickly and you have the e-commerce support. So as compared to like, you know, 20 years back, now it's much easier to launch your product globally.
So right from the beginning, right from the ingredient stage, we help brands, our team help brands to formulate products that is globally compliant. To create labels, to write all the information so that you can, you have, your label is multilingual. It contains a lot of information for different markets so that you can launch as many as market possible just with one cosmetic product label.
Your files, your safety assessments are ready for European market. If your product, I have to say this, I'm bit biased for European regulation, but if your product is compliant for European regulation, especially when it comes to safety of the product, then you can, I think you can sell almost in half of the [00:08:00] markets like, you know, on this planet.
So yes. So we always try to achieve European regulation and then UK regulation. And then US is also like growing very fast. California laws are already very strict. So that's how we do the formulation stage, label stage, safety report stage, and then with the distributor, all the licensing thing. So that really helps our clients to be more confident to sell their products globally.
I think that is what our approach is like basically, yeah.
Deanna: Perfect. That, no, that's super helpful to think about. I'm also thinking though that this project is never done. Regulatory change is certainly a constant in beauty. Are there best practices then that helps, help brands adapt, um, sort of, you know, a generalized strategy for when a change comes along?
Deepa : So the good part is whenever there's a change, whenever there is a new, new regulation, new law is introduced, they always give you time. It's not that [00:09:00] it's announced today and from tomorrow. So they all, you always have a transition period and we always, uh, inform very much in advance to our clients that, you know, see this ingredient may be getting banned after two years, so let's start reformulating.
So from next batch, from next run, from next print, can you just remove this ingredient? Can you just remove this thing on your label? So our clients are kind of ready in advance, and that is what we do. That is how we support our clients. And regulatory is ever so changing. It is so dynamic. It is like, you know, so many new laws, like, again, like there are two, three very strict laws are getting introduced, but somehow we have prepared our clients in quite advance.
Even if you're late, like, you know, authorities do give you time, there is a transition time. So yes, yes, we do help with the change in regulations. Yes.
Deanna: Perfect. And I'm going to show my naivete here. Um, [00:10:00] and I'm curious how a company like yours actually partners with brands. Are you working on a retainer and sort of always available if this new change comes along or is it more sort of a la carte and someone works with you and then they're done and then, oh gosh, there's a change.
Let's hire this company again.
Deepa : No, no. So whoever signs up with us, like, you know, they have, they have also signed up with our newsletter with ... So every now and then, like, almost in twice a month, we send them letters, like, you know, informing what is going to change and what are the, like, new regulations are coming up.
And also the clients who are working with us, they are like, you know, we have meetings every, every other week. So they are very well informed, very well in advance. So that's how ... And we also work on retainer basis, but I think mostly we work pro- project-wise, like, you know, when a client wants to launch 50 products in certain markets.
So like, you know, we, that's how we mostly work project-wise, like from formulation state [00:11:00] to the launch. And then there's a post-launch, uh, cosmo to vigilance as well. Like, you know, we look after the products when they are on shelf. Are they getting any complaint from the consumer? Is there any issue with the authority?
Is there any issue with the customer? We covered that as well. And then any file that we have in our system, we like, you know, keep updating it. So yes, once you sign up with us, we take care of all your formulation, packaging products, everything like, yes.
Deanna: And do you think this business model is relatively standard in the regulatory space?
Deepa : Um, I don't know if I can talk about this.
Deanna: Yeah. No, I'm just, I'm just kind of curious.
Deepa : Yeah. Yes, this should be the ideal way. Once, especially one, if you are RP of a brand, like responsible person, because in Europe and UK, this is a mandatory requirement. If you are selling, you need a RP. An RP name and address goes on the label, every label that is by law.
Deanna: And it's literally a person in that country or region that is somehow- Yes. ... responsible for the-
Deepa : Exactly. Exactly. It is quite different from US. Like after MoCra, US [00:12:00] goes more after the manufacturer, like, you know, who has manufactured. He is more responsible for the safety of the product. But in UK, uh, they want you one legal entity or one person whose name and address goes so that if there's any issue, the authority can correspond with that person.
So for most of our brands, our brands trust us. They just make GCRS as the RP that GCRS please, you take all the responsibility of the, of our brands, of our products that are all around the world. So if we are the RP, we make sure all your products are compliant, they are updated with the new regulations.
The label have all the instruction direction clearly in all the languages, mandatory languages. So this is our standard practice, and this should be ideally like, you know, for all the regulatory companies, they should be the practice. They should keep their customers well informed so that they get enough time to do any changes if required.
Deanna: No, of course. And I, I want to go ahead then and consider how brands adapt to regulatory updates with a, a real example. [00:13:00] I know that you and your team, um, are ready for new mandates, particularly in the EU regarding fragrance allergens, as well as preservatives, sodium ortho, phenyl phenoxide, uh, and other ingredients that are understood to be carcinogenic or toxic to reproduction.
Can you talk about what your team is doing to manage these particular new regulations? How are you guiding your customer brands?
Deepa : So, yes, we have a database of all the ingredients, like, you know, with whichever brand we have worked so far. So we have database of all the ingredients. The moment you enter this band ingredient or like, you know, the ingredient getting prohibited in near future.
So we get list of all the products that is there in that product, and then we notify our customers in time, or we help them to reformulate the product, get another stability. And most of our customers are like, because they want a regulated product, they want a credibility in market, like, you know, the consumer wants to trust the brand.
So most of our [00:14:00] customers have always been very cooperative. We inform them in time, and then we send them a list. Like there is a new, uh, CMR substance prohibition, uh, regulation is coming, and this is effective from 1st of May 2026. This regulation prohibits substances classified as carcinogenic mutagenic toxic for reproduction, and they fall under category 1A, 1B, or two.
So you have like, like silver, nano, and massive multi-wall carbon nanotubes, acidone oxymes. They are in annex too now. I want to tell everyone they now fall in annex to your, especially your color cosmetics. If they contain these ingredients, you cannot put these products in market after 1st of May. And this has been, uh, this is like Omni was 8lis.
So this has been there like from last few months already. The, this is circulating in our news and everywhere. So we have to ensure none of our customers like, you know, have [00:15:00] the products in market with these ingredients. And also as you were saying about fragrance allergen disclosure. So this has been proposed, uh, I believe officially in 2024.
So you have got a good like two, four years time, uh, to reformulate and everything, but our customers, they are well aware of you have to disclose all 82 allergens now. Earlier it was only 27, so now there are more, I think more than 56 new allergens are, uh, introduced. I believe total is 84.
Deanna: Mm-hmm.
Deepa : So threshold on Levon is still 0.01% and for Rinsoft is 0.01%, but common names must align with the latest common ingredient glossary for consumer clarity and market availability for these products, if they're already in market, uh, so you cannot launch after 31st July 2026, but if they are already in market, you can sell up to 31st [00:16:00] July 2028.
Deanna: Mm-hmm.
Deepa : So yes, our consumers, they do get, uh, all the information well in advance, their products, especially if we are RP, all these things are taken care from our database. So yes, that's how we like, uh, keep our products updated, regulated, and it, it is a challenging job, but we love it.
Deanna: Right? No, and, and I can imagine kind of the scenario you're describing, you have the data, so you see which of your customers might need to re- or do- Yes.
in fact need to reformulate. Yes. You can see which of their products need to be reformulated. Yes. I'm wondering too, is there a significant risk of customers launching products with a, an ingredient now that they can't, right? Yes. How do you, how do you sort of safeguard against that?
Deepa : So, I mean, if you have already launched, there is a chance that your products make it recalled, seized and destroyed.
Mm-hmm. So we do not recommend anyone taking this risk, but if you [00:17:00] already have products, like if suppose they are banned in EU market, you cannot sell like, you know, you have to ultimately recall or reformulate your products.
Deanna: And, and if, if a customer maybe is launching an entirely new product and for some reason chooses to use a preservative that has, you know, fallen out of favor because of this new regulation, how do you, how do you catch that?
Deepa : So we have, we do get formulations from our customers. So like, you know, we document everything. Right. We like, you know, get all the documents from manufacturer as well as raw material suppliers. Right. So my team like check each and every detail, each and every breakdown of every raw materials. We also like confirm like, you know, from the supplier itself, from their database, because we have access to some suppliers database as well.
Deanna: Yeah.
Deepa : So yes, we do our due diligence like, you know, and like after so many years we kind of understand that, you know, what this raw material will contain. And we have the database of, okay, this a preservative which is banned now, [00:18:00] so this raw material will contain because this has history of containing. So we kind of double check.
So that's how we advise our clients, our customers, like ... And we never advise to launch products with band. No, of
Deanna: course. But you want to catch it if they create a formula. That, I guess that was sort of my-
Deepa : Yes, yes, yes. Yeah. We, we have a very strict diligence and we have a lot of documents like, you know, they kind of drown in documents.
Amount of documents we ask to check everything.
Deanna: Yeah. That's fantastic. That's fantastic. And you mentioned there, almost coordinating or, or connecting with manufacturers and suppliers, I'm wondering a little bit more about that liaison piece, um, or if you have suggestions about how brands and, and suppliers and, and manufacturers might be communicating about this change, how involved are you or, or what, what happens there?
Deepa : Yes, this is one of the most important, uh, key aspect of what we do. We have to ensure that the brands have right manufactured, like, you know, GMP [00:19:00] certified, all the ISOs have certified. Brands are procuring their, uh, raw materials from the right source. So on my team, we always sort of connect directly with the suppliers, directly with the manufacturers, so that we can liaise with them, ask them the right documents, ask them the right test results, ask them, like, what is updated or what is regulated.
So brands trust us. They just tell GCRS, you communicate because we may not be able to ask the right documents what exactly is needed to make sure that, you know, they are using the right ingredients, they are using the right test method. So we are very much involved and this is like, I think a major part of our job, getting all the right information from the manufacturer, from the suppliers.
Okay.
Deanna: So fascinating. Depa, I, I have to thank you for getting us acquainted. I know there's so much more to learn, but, um, you know, sharing such, such great insights into the regulatory landscape and for being my guest today on Cosmo Factory.
Deepa : Thank you so much. Thank you so much for inviting me. It [00:20:00] was lovely talking to you today.