Message In A Bottle

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Message In A Bottle

Being part of the cosmetics industry is both exciting and rewarding due to the fast pace, fabulous ingredients and beautiful promises. However, clouds can start to gather if you don't understand the rules of the game -rules that are there to protect both yourself and your clients. We are all about the claims and in the world of beauty the line has been drawn. It can feel like there is a lot to take in when things get legal so let's take it one step at a time and work out the who's, where's and why's of claim substantiation. It's as simple as 1, 2, and 3.


  1. The 'wet' stuff.

First of all we are going to look at your formulation. This may be something that you have lovingly created or you may be using a contract manufacturers 'in house' blend. Whichever the case, once you 'adopt' it; it's your responsibility to communicate its features and benefits to your customers. This means that you must take on the task of collecting the appropriate evidence for any measurable claim that you make (for example, a claim of 24 hour moisturizing would have to be tested by your company unless you are given the test results for the third-parties formulation and even then it will only be applicable if you have not altered it in any way that may affect its action).

In addition many brands come unstuck when they list that their formulation is 'free from' a wide range of additives without having a procedure in place to manage and control this. It may seem difficult to get manufacturing flow charts, ingredient origin information or process controls from third party manufacturers but it needn't be. Always use reputable contract manufacturers who have quality procedures and controls in place to measure and track changes in ingredient quality, additives and origin. Remember though, it is YOUR responsibility to make your brand philosophy known BEFORE you commence manufacturing and it is YOUR responsibility to advise the manufacturer of any changes that you make to your position.

Finally many people wish to certify their range under a 'natural', 'organic' or 'fair trade' banner. Again, this decision or brand strategy should be communicated to the manufacturer as soon as possible as certification criteria and regulations vary from country to country. Buying an off-the-shelf organic range can be popular and can short-cut the length of time taken to get to market. However, once purchased and re-branded you have to be able to back up any origin based claims that you make which again, should be easy if you choose a reputable manufacturing partner.

EVIDENCE, EVIDENCE, EVIDENCE.

  1. The Brand Collateral.

Secondly you have to make sure that you communicate those features and benefits in accordance with the cosmetics labeling guidelines. This is where your label, website and brand collateral come in. NICNAS and the ACCC can help give you an idea of what is acceptable but for products that are close to the line it would pay to get professional advice from a Regulatory consultant (one such place being the Institute of Personal Care Science).

It is very tempting to get carried away and call your product 'magic whitening and wrinkle removing cream with deep acting skin nourishing antioxidants that stimulate collagen synthesis' but claims like that won't fly under the current cosmetic legislation. Anyway, if they did, you would need to provide the evidence again...

Message In A Bottle

ATTENTION TO DETAIL.

  1. The Staff, online and off.

Sometimes the hardest part about selling your product is avoiding getting carried away in an interview about what it can and can't do. Yes we know that you know that your wonder cream will turn back 60 years of sun damage and do your washing up but unless you have that scientific evidence again, words like that can get you into trouble. Take the time to understand your recipes, their strengths plus their weaknesses and make sure you stay within that fence when promoting them. Don't make promises that you can't back up - for example, saying that your lavender comes from a small village in Bolivia when it really came from Bathurst may seem like a small problem but it can lead to suspicion as your customer wonder what else you got wrong.
It also pays to think about how you will communicate your brand virtually. The rise of facebook, twitter and blogging mean that your brand can grow a personality of its own if you don't manage it and unfortunately that can backfire.

TRAINING, MENTOURING AND UNDERSTANDING.

After all that you could be forgiven for feeling like you have to become a control freak to play this game. Well, it's not that bad really but after all the work, excitement and glamour has died down you will find that it is the confidence in what you are selling that sustains and inspires you to go on. It's all about 'owning' your brand and making sure it is growing up strong!
While New Directions are not responsible for any claims that our customers make we are more than happy to help provide you with the information and guidance that you need to succeed. In some cases this will mean referring you to third party consultants or experts who can offer you the appropriate legal and technical advice or provide you with the required amount of evidence to substantiate a claim.

Amanda Foxon-Hill

22 Oct 2010

More about: Cosmetics

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