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From the UK to Canada and back again: sharing cross-border best practice for placing cosmetic products on the market
Colleagues at CTPA and Cosmetics Alliance Canada share their collective take-aways from a recent joint webinar.
As more companies of all sizes seek to go global with their cosmetic and personal care products, experts at the CTPA and Cosmetics Alliance Canada came together recently to host a joint webinar on the key considerations for placing products on the market in the UK and Canada. What’s the same? What’s different and what are the watch-outs?
Carys Ayton-Smith, Regulatory Affairs Manager and Francesca Rapolla, Scientific Affairs Manager at CTPA alongside Darren Praznik, President and CEO, and Beta Montemayor VP, Director, Science Regulation and Market Access at Cosmetics Alliance Canada (from left to right below) reflect on the key questions raised during the webinar, as well as what future collaborations could look like…
What was the thinking behind the joint webinar?
Last year when CTPA was presenting at the 12th World Congress for Alternatives to Animal Testing in Canada, our associations had the opportunity to get together to compare notes on the challenges and opportunities we are navigating in our respective markets, and the services we offer to our members to respond to these.
It turns out that, despite the physical distance between us and some differences in regulation, there is a huge amount of shared ground between the UK and Canada. So we landed on the idea of a joint webinar where we could share our experiences with companies in each market and test the water for further collaborations in the future.
On the UK side in particular, CTPA has observed that post the EU exit, companies of all sizes are looking at markets further afield. The webinar was an opportunity to introduce UK companies to the size and shape of the Canadian market - and to get granular about how to approach placing products there.
What topics does the webinar cover?
We cover ten key principles of the UK Cosmetics Regulation for companies to review when looking to introduce products to the UK or Canadian market, as these cover key legal requirements to be met. These principles traverse the process from end-to-end, starting with the definition of cosmetic products in both markets, through to safety and ingredients requirements, labelling, claims, cosmetovigilance and finally market surveillance.
For each of the ten principles, we explore the similarities and differences in regulation and approaches taken in Canada and the UK. It all adds up to a really comprehensive overview of what to expect if you are planning to enter either market.
What are the priority issues for Canadian and UK companies?
While the questions we received were far-ranging, it’s clear that there are some stand-out priorities for companies.
The nuances of Northern Ireland were a hot topic for Canadian audiences. For example, which regulations apply in Northern Ireland and whether, if a product is sold in Northern Ireland, it has to comply with the UK or EU regulations? There were also questions about whether the safety assessment of a product sold in the UK market can be conducted outside of the UK. (The short answer to this is yes, subject to some specific requirements).
Meanwhile, UK audiences had a wealth of questions about labelling, in particular, how to navigate French/English dual language requirements and how to tackle names or logos, with heightened interest due to the implications of Bill 96, a language law in Quebec, on language requirements and regulations for labelling in the province. Wider labelling queries included when Canada is going to finalise the requirements for labelling allergens on cosmetic products, what those allergens will include, and whether non-Canadian addresses can be used on products sold in Canada.
The use of CBD was a popular topic too because of the regulatory differences between the UK and Canada. Under the Cannabis Act, many activities with CBD remain prohibited (including cosmetics) in Canada, except for the specific cases authorised by the Act and its regulations.
Can we expect to see more collaboration between CTPA and CAC in future?
The level of interest in the webinar from companies on both sides of the Atlantic has highlighted the appetite for us to do more of this, so we’re exploring what that could look like. From the Canadian perspective, a lot of what happens in the UK carries across into Canada so Cosmetics Alliance Canada and its members certainly benefit from being across changes in the UK market.
From a UK perspective, Canada is leading from the front on important issues like NAMs (New Approach Methodologies) for safety assessments so there is a lot for the UK to learn and benefit from through more collaboration in this area. Understanding how Canada is making progress can help to promote regulatory acceptance in the UK.
In short, watch this space for what’s next - but expect to see more collaboration and information-sharing that crosses borders.
CTPA members can catch-up on the webinar here.
