If any of you caught the BBC documentary, The Truth About Looking Good, a couple of weeks back, you’ll understand why the rise in cosmetics and the claims supporting them are now under the spotlight. With the increase in attention from the public and the media, manufacturers are stepping up and acknowledging the growing scrutiny of public perceptions.
Market research shows that the cosmetics industry is experiencing huge growth, with no signs of slowing down. According to an article which appeared in the Independent last year, cosmetics is now the top-performing category within UK health and beauty, and sales were up £55m in the year to 18 March 2017 compared to the previous 12 months, and up £100m on 2015.
With the rise of cosmetic sales, makeup artistry, bloggers and vloggers, the next generation are becoming less brand loyal and are relying more on the bloggers and endorsements to support their spending decisions.
The BBC documentary really honed in on the fact that the claims made about products are supported by limited scientific evidence. In fact, it specifically pointed out that to claim a product is dermatologically tested, it technically only needs to be tested on one person. Even the extent to which a product is effective can be exaggerated, with negligible affects used to make bold claims.
With rising sales, willing consumers and a low regulatory barrier to market, it is not surprising the market is expanding with new players entering all the time. But how reliable are these and how can manufacturers claims about their products be made to hold more weight in the public eye?
Some of the big name stories come from the Federal Trade Commission’s rules regarding celebrity endorsements. Products that are not genuinely used by celebrities themselves; that they have been paid to promote; sent free samples or have a close relationship with the brand / person, need to now be clearly identified as advertisements on social media. According to a BBC article, this intervention was part-prompted by the advocacy group Public Citizen which named celebrities, including Kim Kardashian, for sharing products on social media without disclosing the endorsement. With this now being much clearer to consumers, the weight celebrity endorsements hold, will almost certainly lessen.
This leads us to why the need to have meaningful clinical data can be vital, not only if the regulatory authority come knocking, but also to keep consumers happy. A clever marketing campaign and exaggerated claims might be enough to get a product out there but savvy consumers will soon move on if they aren’t seeing the benefits.
The regulatory burden does not simply stop with claims. Take for example the recent move to ban microbeads from UK products. Companies need to be aware of changing regulations in every country they sell a product. Being prepared and on top of trends and changes is critical. Companies need to be in the know and invest in the R&D to update and modify products as required to ensure they are in line with legislative requirements.
What’s legal in one country, may not be in another. A good example is the use of hydrogen peroxide in toothpaste in the US, which is banned in the EU at greater concentrations than 0.1% (between 0.1% – 6% can only be sold by dental practitioners, or under their prescription). The ever-changing landscape poses challenges and threats to many manufacturers operating worldwide.
With Brexit moving ever-closer, and other countries having their own regulatory authority, the cumulative position presents its own difficulties. As with the pharmaceutical industry, cosmetics regulation is aligned with the EU. As we leave the EU, the UK pharmaceutical industry will have the MHRA to provide a framework and guidance during the transition. It is difficult to see the network of local Trading Standards Offices, which regulate the UK cosmetics industry, being able to provide the same level of support.
This presents just another reason why continued regulatory oversight is going to be vital.
It is not just the regulatory framework that provides risk to an unwitting cosmetics manufacturer. Quality, or lack of, can also pose a risk to a cosmetic product. A limited stability study may be enough to establish a shelf life but, if it doesn’t properly reflect ‘real world use’, then it may be worthless. Moving manufacturing to another factory may help increase the margin on paper but, without a proper technical transfer, you may end up with an inconsistent and unwanted product. Often companies test a small section of the bulk product in comparison to pharmaceuticals and their stringent test methods which ensure rigorous testing.
It is all too easy to dismiss the physical risks posed by cosmetics products. If there is micro-contamination in a product, it can be hugely dangerous. Hair care products leading to hair loss; eye makeup causing blindness; creams resulting in blood poisoning. These are extreme circumstances that could lead to a company’s destruction but it is important to acknowledge the risks that come with cosmetics.
It is also worth considering the increase in reputational damage that can arise with cosmetics. A low-risk adverse event such as a rash from a pharmaceutical product goes by mostly unnoticed in the media. Whereas a rash occurring from a makeup product may be blogged, discussed and read by the masses causing huge reputational damage and loss of sales.
This is why many of the big manufacturers are doing extensive due diligence. They know the industry is growing. They know consumers are looking more in depth at products and their claims. They understand the need to be following the regulations but going above and beyond.
This brings us to why some of the smaller manufacturers who sell products more exclusively aren’t always the best. Smaller salons, etc., don’t necessarily have the resource to audit their suppliers; so may not always have the best, safest and most effective products available. Losing a supplier like Boots is a disaster, losing a small salon in a town isn’t going to set you back millions. The moral of the story: the most expensive aren’t always the best.
Doing the due diligence, following pharmaceutical guidelines and doing more than the bare minimum may cost more in the short term but in the long term could be a huge saviour for your brand. Consider using external experts if you don’t have them in house. Audit your suppliers, test your products extensively to support your claims and keep up to date with legislative guidance.
While the regulations are less specific for cosmetics, don’t be fooled that this is necessarily a good thing. If you don’t understand the regulations that govern your product, the science that supports it or the process that manufactures it – your product is at risk. You could end up appearing on Watchdog or being investigated by Trading Standards if an adverse reaction is reported. Having done the leg work, you can prove that your product is safe to use and help satisfy consumer complaints with peace of mind.