Customs data shows that in the first three quarters of 2023, China’s exports of cosmetics and personal care products amounted to 34.861 billion yuan, marking a cumulative year-on-year growth of 26.6%. China’s cosmetics exports are thriving.
At the same time, how Chinese cosmetics brands evolve from quantity to quality, and their positioning on the international stage, has become a new topic of this era. During the 2023 FORUM ON BEAUTY ECONOMY AND SUSTAINABILITY, ONE OF ZGC FORUM SERIES OF ACTIVITIES, the “Trends Discussion” column, with a keen eye, interviewed representatives from ASEAN member countries such as Myanmar, Thailand, Malaysia, as well as leaders of cosmetics industry associations from France, Europe, and other places. They dissected global trends in the beauty market and key regulations, aiming to support companies in their international expansion. During the forum, Gerald Renner, Director of Technical Regulatory and International Affairs of Cosmetics Europe, granted an interview to CHAILEEDO.
CHAILEEDO: In Europe, there has been an ongoing process toward banning animal testing for cosmetics could you please tell us some alternative methods to animal testing in Europe?
Gerald Renner: It’s not new that that was introduced years ago, and it has been fully implemented for ten years. Of course, when it was implemented, it was at a time when alternative methods did not exist for all safety. Safety tests that we need for new ingredients.
In the meantime, there has been a lot of progress. And today we are in a situation of local toxicity. Skin irritation, eye irritation. Skin sensitization in all those areas, we have alternative methods. There is no need to test on animals.
For some other endpoints, like systemic toxicity. We’re not necessarily there yet that we can easily. Demonstrate the safety of new ingredients with alternative methods. That means we still need to do more work to go further and develop the methods for systemic toxicity.
CHAILEEDO: In terms of regulations and market size, the European Union (EU) has always been at the forefront of the global cosmetics industry. Therefore, Chinese companies have also paid great attention to the restrictive measures from the EU on ingredients such as retinol and arbutin in recent years. What are the key focus areas for cosmetics regulation in the EU or Europe?
Gerald Renner: On ingredients, we have two focus areas I would say at this moment. One is endocrine disruptors. One of the new pollutants that was mentioned at that conference. for those the commission established a priority list of substances that could potentially be endocrine disruptors, and that could be used in cosmetics. And they came up with a list of 28 substances. For the last five years, we’ve been working through that list, and identifying the substances which are used in cosmetics.
We’ve prepared safety dossiers, and we’ve submitted them to the European Commission, so for the last few years, there have been a lot of scientific opinions coming out. And this will continue still. And there are several UV filters. There are some preservatives. There are some antioxidants. That is on that list, there are even some plant extracts.
And those substances. Some of them are already regulated. For some of them, the regulation may change. For some of them, the regulation may be just maintained as it is. Some substances are not regulated, like the antioxidants for which there will be a restriction that would be regulation.
The substance most famous is BHA BHT antioxidants. They are under evaluation, but I have to say a lot of those substances have already received opinions from the scientific committee. And practically all the cases, the scientific committee conferred.
Safe as currently used or safe with minors. Stronger restrictions so overall on this priority list, which is a lot of work to work through. But we come out with a picture that these substances, although they are potential endocrine disruptors, can be safely used in cosmetics. And we get that confirmation now.
The second focus is not on material Because we have a regulation that says if a product contains a new nanomaterial for the first time, this nanomaterial needs to be evaluated. And so we have several nanomaterials in the discussion. The fullerene and titanium dioxide are coming again and again. Always new questions that come up.
Synthetic amorphous silica, which is very widely used in toothpaste, is very widely used in makeup It’s a powder, and this is under evaluation as well.
CHAILEEDO: This conference will explore issues concerning cosmetic safety assessment, which is currently a focal point in Chinese cosmetic regulations, could you share some advice or suggestions based on your experience for companies to consider?
Gerald Renner: The safety assessment, if I start with a recommendation for China, maybe not for the company it is, is a recommendation that our experience was thirty years ago. When safety assessment was introduced in Europe as a legal requirement.
There was a transition time of three or four years. It was impossible to do it at such a great time. To have 5000 companies gain the knowledge and experience to do a quality safety assessment.
It takes time. So that’s the only that’s the first important message. It will take time in China to fully implement such a safety assessment, it’s not by setting a date in two years that it will be achieved. It will need a lot of training; it will need to build up the infrastructure and network of safety assessments. Don’t be ashamed that the deadlines that may be put in regulations will possibly not be met. They are extremely ambitious and from a European perspective. I cannot see how this is possible. It just will take time.
So, the recommendation at the moment would be to invest in training in the training of safety assessment, not every company must have its safety assessment. There can be third-party safety assessments, but you will need a big community of safety assessments to deal with all the products that will be assessed.
So, they need to be trained. The authorities and the evaluators need to be trained in how to read and understand such safety assessments. The safety assessment takes all the data, new data, data according to standards, and data that was just research data. And then a good safety assessor looks at all that and he can conclude.
These are things not how operating in a pre-market registration. You see you have to have these tests. Yes, yes, yes, notice is missing. No, he tested there. This is not how it will work with Safety assessment. Safety assessment has to look at all the data you need to experience the expertise and then be able to draw a conclusion and as I said, it will take time to gain that experience, to build that experience and the network of people who can do that.
CHAILEEDO: How about companies in the EU?
Gerald Renner: It took time. We have had the obligations for thirty years and the companies have established the experience. There is a wide network of consultants who do third-party safety assessments, so it has become a practice and is working.
The training is taking place and very often we have training courses when the authorities come together with the industry. And they get the same training so that everybody knows what needs to be done and they have the same level of understanding.
I think that China is going in the right direction of going to a full safety assessment. But the transition will be difficult, and there will be a time, probably, when some companies are able to do it. And some companies are not yet able to do it.
And China needs to find a possibility, that gives the time for those companies who still need to develop. But it shouldn’t block the companies who already can do it.
So there will be some very important steering that needs to be done by the authorities to push those who need to learn quickly. And enable those who can already do it to use it to go on the markets.
CHAILEEDO: What are the key concerns of the European cosmetic companies regarding Chinese cosmetic regulations and the market at present?
Gerald Renner: The concerns, I would say, If I summarize it in one or two sentences, is that We have an experience in Europe, we have a very high input safety record in Europe, we have data to support the safety in Europe and the efficacy of the products. But when we go to China, we still need to do additional work and I think it’s this not acceptance, necessarily, of something that is already at a very, very high standard.
In China, we need to duplicate work specifically for the Chinese. We need to redo some testing because it has to be done in China. We had to redo some testing because we were following an international standard, and we didn’t follow the Chinese standard. So these China-specific issues are very often cumbersome and difficult because simply it means additional resources that we need to spend. That is certainly one issue.
I understand where China is coming from. It is the uncertainty. We know the Chinese standards and that works. So now accepting a product according to an international standard is a big step for China. But I think ultimately it would be necessary to take that step and accept international standards because China wants Chinese companies to export and based on the Chinese standard, maybe the products will not be accepted, but based on international standards, they will be. So, I think it’s a logical evolution. One day China will go further and accept international standards, but at this moment this is certainly an issue.
Everybody is worried in the future about the safety assessment that maybe the European safety assessment, as it is done today, might not be accepted in China.
One issue is labeling. That’s the way people interpret the labeling requirements in China. It may mean that we cannot keep the original packaging and adjust it statically. But in practice, it may mean that we need to do China-specific packaging, and that would be a huge cost.
CHAILEEDO: Okay, so what difficulty do you think? Chinese cosmetic companies to go export like to Europe.
Gerald Renner: I think that doing it in a Chinese way not necessarily will be accepted in the rest of the world, so.
Again, Chinese companies will have to duplicate the work as well. Do it in the Chinese way for China, and they need to redo it the international way when they want to go to the US, to Europe, and so on.
I think a lot of it does not understand the European cosmetic regulation. Because China has grown up in a very different regulatory environment. So, just now going to the European market, means a lot of change in the mindset.
It is possible, but I do believe that it is not extremely difficult. But you need the understanding. I think a lot of Chinese companies struggle with the animal testing ban. In Europe, we have learned to live with it. We know what we are allowed to do, what we’re not allowed to do, and what we’re not allowed to do is animal tests. We complimented. We know how we can use the alternative methods because we had ten years of head start to deal with that.
So again, I think a lot of companies in China might be scared because they also misinterpret the ban in Europe, they think everything is bad. I can do nothing and that’s not true. Otherwise, we wouldn’t have a very good business that we have in Europe at this moment. So I think a lot of it is simply not understanding well enough.
Some people can help in this understanding. I always say I look forward to the time of the day when the first Chinese company becomes a member of Cosmetic Europe because that means a Chinese company has been successful in the European market and can become a member of the cosmetic group. I know that day is not far anymore.
CHAILEEDO: The last question is from a legal and regulatory perspective, what challenges do European brands face when entering China and what challenges do Chinese brands encounter when entering Europe?
Gerald Renner: I know that in the nineteen nineties in the early 2000s, there were maybe some strict legislations in China, but they were not enforced. Entering the Chinese market was, or they were enforced very flexibly, very, very likely. It was possible to quickly and easily go on the Chinese market.
since 2010 I think China has been applying its law and that made a lot of difficulties already at the time because people didn’t understand these Chinese legislations correctly. And there were a lot of quick changes. I think some small companies, are overwhelmed by them. It’s too much. There are too many changes. They cannot adapt so quickly.
I think until it is fully implemented, then everybody knows what to do. We will see fewer companies withdrawing because they say at this moment it is too difficult, and there is too much uncertainty.
To go to the Chinese market is to go on because I don’t know if, will my accepted. Yes. No, will my label be accepted? Yes, I do market, but I don’t know if it would be accepted in this legal certainty. Which is missing because it’s a new regulation. Maybe even the authorities don’t know yet how they will apply everything. And the worst thing for business is uncertainty.
