INTERVIEW
“It seems every country is making the regulatory hurdles higher so that it is more difficult for the outside world to enter their
domestic market.” Mike Sohn, general manager and principal consultant, REACH24H Korea
what’s called the safety substantiation, has been strengthened.
TP: Oh yes, it requires a designated ‘responsible person’ to demonstrate that a cosmetic product is safe, backed up with evidence like study data and so on. MS: Yes, so it’s definitely become more difficult. Before MoCRA, there was no facility registration, no product notification. Moving forward, MoCRA will become more
stringent. There will be mandated rules about cosmetic GMP (Good Manufacturing Practice) by the end of this year. They will also introduce allergen labelling
regulations. But, of course, MoCRA is federal law
and there are also state laws that cosmetic companies have to stick to. In effect, there’s 50 different MoCRAs. Take
California, one of the biggest cosmetics markets in the US. California’s Proposition 65 requires warning labels on cosmetics products sold in the state if they contain chemicals known to cause cancer or reproductive harm. Or Hawaii. In some counties of Hawaii, there is a ban on all chemical sunscreen ingredients. Only mineral-based sunscreens with non- nano zinc oxide or titanium dioxide are allowed. This is very restrictive for companies who want to sell sun care products. In Washington, they have the new Toxic-
Free Cosmetics Act. This prohibits cosmetics containing intentionally added lead or lead compounds, or lead impurities over 1 part per million (ppm). So, state laws can make it more difficult to
enter the US market than federal law. The other thing with the US is that sunscreen
and even anti-dandruff shampoos are consider OTC (over the counter) drugs by the FDA (US Food and Drug Administration). That means companies and their facilities
have to comply with OTC drug regulations, which can also be very difficult.
TP: How about the European Union? MS: The European Union (EU) tends to bring in brand new regulations in the global market, which means it’s one of the more difficult markets to comply with. There are recycling regulations for plastics,
like microbeads. Packaging safety regulations, animal-alternative testing regulations. It’s not just cosmetics-specific regulations
to comply with, there’s sustainability-related regulations like the Green Deal, which aims to make the EU carbon neutral by 2050. And like the US, each country can have its
www.personalcaremagazine.com November 2025 PERSONAL CARE
17
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96 |
Page 97 |
Page 98 |
Page 99 |
Page 100 |
Page 101 |
Page 102 |
Page 103 |
Page 104 |
Page 105 |
Page 106 |
Page 107
