Premium Beauty News - What are the areas where you bring your contribution the most?
Sylvain-Romain Cotte - After having spent many years in the industry, I created my company, at a time when regulations on cosmetic products were becoming considerably more complex in Europe. On the one hand, the ban on animal testing had been planned and secondly, authorities were setting very ambitious standards in terms of safety and scientific knowledge regarding substances used by manufacturers, in particular with the adoption of REACH.
In co-operation with the French Federation of Beauty Enterprises (FEBEA), I assisted the first French companies who initiated audits to test the compliance of their manufacturer premises with Cosmetics Good Manufacturing Practices (GMP) [1].
Needless to say that for SRC Consulting, work was plentiful.
We operate in areas as diverse as:
– organization, by audits of organization for regulatory affairs,
– compliance with French and European regulations (audit, setting-up and management of European legal records on products, assessment on product safety for human health, regulatory validation of communication media and advertisement),
– support for the launch of products on overseas markets,
– Good Manufacturing Practices (GMP) for Cosmetics (audit of industrial sites with regard to GMP Cosmetics, accompanying the action plan for compliance),
– regulatory watch (setting-up of a customized regulatory watch, …),
– training (in a number of schools and universities and through in-house training).
Premium Beauty News - In this increasingly complex regulatory framework, what are the main difficulties encountered by companies in the cosmetics industry?
Sylvain-Romain Cotte - Strangely enough, in a world where information sources are more and more available, I feel that the biggest difficulty is finding the right piece of technical information and, above all, to be able to transpose it into industrial practice.
Hence the need to get support from experts, but here again, it is not easy to be accompanied by the proper consultants, the ones that have the “industrial reflex” that is to say the knowledge of the operational capability of the company.
Then I think the final difficulty is to analyze and assess the risks of regulatory non-compliances to make the proper decisions.
Premium Beauty News - What are the regulatory "emergencies" of the moment?
Sylvain-Romain Cotte - As far as France is concerned, undoubtedly the implementation of GMP for Cosmetics. The “Made in France” must be the benchmark for quality in the cosmetics and perfumes industry worldwide. Then, information and application of the new European Regulation on Cosmetics, and eventually the regulatory watch on ingredients and data computerization.
Regarding GMP, operators are now at the budgeting stage, either as manufacturers, for the implementation of the text and to obtain the certification, either as brand owners, to delegate outsourced audits.
Premium Beauty News - What will the entry into force of the European regulation change?
Sylvain-Romain Cotte - It will first help clarifying responsibilities of the different actors in the sector, what is going to change in their relationship. It will often involve a new organization of companies in terms of setting-up and management of European legal records. It also changes the assessment of the product safety. Eventually, it will, in my opinion, encourage in some cases a rationalization of raw materials in the catalogue!
Premium Beauty News - You are launching next month in Paris, Les Matinales de la cosmétique ™ (The Mornings of Cosmetics), can you tell us more?
Sylvain-Romain Cotte - In a fairly difficult economical situation, I wanted to create a new concept in professional meetings, both friendly, relevant, operational, effective and economic on highly specific topics related to the cosmetic industry. The number of participants is intentionally limited in order to stimulate discussions.
The themes addressed will not only be on regulatory issues, they will also concern subjects related to other issues such as markets, distribution, sustainable development, etc.. with each time, participation of key experts.
The frequency of Les Matinales de la Cosmétique™ will depend on the needs of professionals, they will probably occur on a monthly basis.
The first meeting on Tuesday November 17, 2009, will specifically focus on the theme: "European Cosmetic Regulations: The obligations of the liable person".
I therefore invite all interested professionals to join me at 14 Avenue Georges Mandel - 75116 Paris (Metro Trocadero) from 8.00 sharp (opening at 7:30 am) to 9:45. The participation fee is 50 € per person. And do remember that seating is limited to 15 attendees. For more information: contact@src-consulting.fr
For this first event, I will moderate the meeting with the participation of a surprise speaker, a manufacturer from a prestigious French cosmetic company. The second event, is scheduled on December 15, 2009, on a very operational issue too.
