Valérie Colin, Regulatory Affairs Director of FEBEA (left), Zhaoyang Cai, Founding partner of Chaileedo (right)
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, Valérie Colin, Regulatory Affairs Director of FEBEA, granted an interview to CHAILEEDO.
CHAILEEDO: In 2022 China became the largest importing country for cosmetics from France. What differences and similarities do you see in cosmetic regulations between China and France?
Valérie Colin: There is a big history in France with cosmetics. FEBA is a very old federation. It was created in 1899, a very old story, and France was the first country who write regulations but cosmetics in Europe. It is coming from France. Then it went to Europe, it became European regulation. That regulation is widely recognized and is a reference for many countries at the international level. That’s it’s important to understand our France is involved in all of those regulations and as a kind of leadership in older discussions.
I will first present what we agree on because I think it is also important and we have the same goal. I mean, at the very end we all agree, France and China and Europe that we need to ensure the safety of consumers.
That’s fully agree with that, and I think we can both achieve that having said that we have different ways of achieving the goals, we can have any commercial exchanges because we agree on those goals, you know, France is very present in China and this is historical. China is very interested in the advanced technology that we have in France, and we know that we have something on that and that we are closely working together.
When we say that, what are the differences, what I was saying, is the differences are not in the goal because we agree the differences are and the way we achieve the goal and those are extremely different. I will not list all of them. I will just give you the highlights. First, we have what we call the responsible person and the responsible person most of the time is a Moral entity and is not a physical person. In China, you allocate responsibility to a physical person. In Europe we allocate responsibility.
Most of the time this is a Moral entity, and the other difference is that the responsible person will be responsible for compliance with the overall regulation, which means that the responsible person has the responsibility of the safety assessment and the G M P as well, it’s the same entity. So that’s the first, the first difference.
But in the spirit, there is the idea that we need to have someone responsible for that. It’s the way we implement that, that is different.
The other difference is that in Europe, a cosmetic is a cosmetic. We don’t make any difference between different kinds of cosmetics. But what we do is that we have an ingredient management system that regulates the safe use of ingredients in cosmetic products. It means that, for example, we can manage UV shelters and there is a positive list for the use of UV shelter preservatives. And there is on the other side, a forbidden list of ingredients you shouldn’t put in a cosmetic product.
That’s a second big difference in terms of the way we manage the cosmetic products and another point you may hear a lot if you look at Europe is that, you know, we are not a lot to do animal testing in Europe. There are a lot of developments in terms of tests on alternative methods and that’s a big subject in Europe for us today.
Then I have two other items, you know, labeling requirements. We have very different labeling requirements that lead to a lot of discussion because we need to stick to the box. We need new and that is creating and generating waste. That’s why there is a lot of discussion on that between, you know, France and China and we manage also, and I will stop with that because I won’t last, but, you know, claims in Europe should be justified to justify the claims you need to do.
Test and you need to use international norms to do the test. Today, you know, we may have to do the test again or we cannot use the claim so that’s also, you know, on the way we manage to claim and the test that we have behind where we are not following the same regulation. I will stop here because I don’t want to give a full list, but I think that’s the main highlight.
CHAILEEDO: This April, President Macron visited China and signed a series of cooperation agreements, notably highlighting both country’s commitment to fostering a conducive environment. For cooperation in the cosmetic industry and improving market access for business in each country, and each other’s countries, what legal and regulatory considerations should Chinese cosmetic brands be aware of when entering the French market?
Valérie Colin: The French industry is very happy to see that there is this high-level dialogue in place, and it references the importance of the relationship between our two countries. It shows that this dialogue is necessary when the regulatory framework is evolving that’s essential to talk together.
France has tended to have very strict regulations in many fields. I’m not talking here about, cosmetic regulation, but I’m talking about, for example, the regulatory framework, dealing with consumer information or all, all the text around sustainability.
And sometimes France is ahead of the EU regulation. And we have to face that challenge also. What is important to understand is that our consumers in France, also expect that we follow the rules because what is dealing with their information and what is dealing with the environment is very important to them as well.
We are talking about sustainable products and we are talking also about packaging. This is very, very important, sustainable products and packaging.
Chinese company needs to understand that they will have, of course, to follow the regulation dealing with the regulation dealing with cosmetic products. But they will also have to follow those regulations specific to trends around consumer information and around what is, you know, requested in terms of packaging and sustainable developments. as well.
CHAILEEDO: We also heard that some Chinese companies are not familiar with the EU regulations and they can’t understand the EU regulations, do you think what are the difficulties about this? Is that a language barrier?
Valérie Colin: It may be language barriers. Maybe it’s difficult to go into all the details and that’s why we need that because I can tell you. The French and the European perspective, maybe because it’s the same for Chinese people. There are many things we need to duplicate to go into the Chinese market. For example, in the tests, we are now following international law which is sometimes not accepted in China.
It means that we need to duplicate, we need to understand your law and you need the contact at the laboratory to do that. And that’s not easy. It’s the same for a Chinese company. We face the same issue on the other side and that’s why we want to have that discussion and to agree to simplify the burden associated with that.
CHAILEEDO: What role do you believe the French cosmetic regulatory policies and regulations play in fostering the development of the cosmetic industry and maintaining its leading position in the global market?
Valérie Colin: France today is a pioneer and the leader for the ecological transition of the cosmetic sector, because we have those rules, you know, as well we’re saying France in terms of regulation, as when France is sometimes ahead. It means that the cosmetic sector is also ahead on that. We have the kind of leadership for that. And it’s a movement of all the sectors, big companies, small companies, they are all in that movement.
We knew how to do safe cosmetics, we knew how to do good quality cosmetics, and now we know how to market sustainable products. If you can summarize that, France is the leader in cosmetics and France is targeting to be the leader in sustainable cosmetics. That’s the way we present ourselves.
CHAILEEDO: How do you think cosmetic companies should adapt to the differences in cosmetics regulations and loss when expanding into international markets?
Valérie Colin: We discussed that already a little bit. But cosmetic comes, you know, they will have to comply with each of the regulations and laws. When Chinese companies want to enter into the French market or the European market, the same process we’ll have to comply with new regulations and understand the French specific, you know that uh the EU regulation in some piece of the regulation it gives to national competent authorities. Some duties for example the surveillance of the market. Then we have to understand that for the claims, for example, you know, and the inspection they can check the product and the content of the product that they can check also the claims. You know you need to understand the spirit that you have those are written so that’s what I mean you are supposed to do.
