Anticipate, monitor, and adapt: the keys to navigating trade barriers and regulatory changes

The cosmetic industry, a showcase of French expertise, plays a key role in promoting France internationally. In 2024, French exports exceeded 20 billion euros, representing 60% of national production. However, this success faces an uncertain international context.

Indeed, the cosmetics sector faces a resurgence of trade barriers—tariffs, quotas, import restrictions, or specific requirements—that exert growing pressure on the supply chain. At the same time, the rapid and heterogeneous evolution of regulations complicates formulation and sourcing strategies. In this context, cosmetics professionals must rethink their approach to ensure resilience, compliance, and product performance. Cosmed highlights several levers that can be activated to mitigate the impact of these obstacles.

Trade barriers and supply chain

The trade war between the United States and China, geopolitical tensions, and the rise of protectionism complicate access to previously more open markets. SMEs, in particular, are vulnerable, as they rarely have the resources to adapt to these changes.
Indeed, the United States has imposed new 10% tariffs after a 90-day suspension of the previous 20% surcharge on European products. China, for its part, has tightened market access conditions through its CSAR regulation (Cosmetic Supervision and Administration Regulation), introducing stricter requirements for safety assessment and product registration.

In this context, three strategic actions can be implemented by companies:

1. Use of free trade agreements
   The European Commission has concluded 44 free trade agreements covering 76 countries. These treaties offer tariff advantages—removal of tariffs, simplification of procedures, protection of intellectual property. For example, In Canada, the CETA, allows for 0% tariffs on certain cosmetics if conditions are met. However, these opportunities remain underutilized due to a lack of knowledge and/or resources. Platforms like access2markets developed by the European Commission can help industry players familiarize themselves with these tools.
   
   
2. Regionalization of the supply chain
   Some companies are relocating or regionalizing their sourcing to limit logistical risks, circumvent certain tariff barriers, and better control timelines. This strategy can, however, involve a limited choice of ingredients or increased costs, particularly for raw materials specific to certain climatic zones. It sometimes requires adapting formulations to maintain performance and sensory qualities.
   
   
3. Collective mobilization and sector coordination
   Professional associations like Cosmed play a crucial role: they relay the difficulties encountered, support European initiatives, and promote the pooling of efforts.

Multiplication of regulations and formulation

Regulatory requirements, which are constantly evolving, make cosmetic formulation more complex. Indeed, each country applies its own regulations, often divergent, complicating the development of "global" formulas. The European Union, for example, is regulating on controversial substances (microplastics, PFAS, certain preservatives).
In the United States, even though the MOCRA reshuffled the cards at the end of 2022, regulatory complexity mainly rests on states, such as California, Washington, or New York, which impose additional regulations on ingredients, transparency, or the banning of animal testing. This duality complicates compliance at the national level and indirectly forces brands to aim for the most restrictive requirements.
In other strategic regions like China, constraints are both technical and procedural: ingredient registration, toxicological documentation, marketing restrictions. Indeed, the CSAR has changed the rules of the game with increased accountability for local actors.
Furthermore, certain cultural constraints—such as halal certification in the Middle East and Indonesia—also influence formulation.

To address this diversity, formulators adopt a "modular" approach: developing a base formula that can be adapted according to the requirements of different markets. This allows for cost and time optimization while ensuring broader compliance. However, this approach requires constant regulatory monitoring and close collaboration between R&D, regulatory affairs, supply chain and marketing. It is important to note that professional associations like Cosmed work towards the adoption of reasonable timelines for companies, particularly SMEs, to allow them to comply and avoid product destruction. Staying informed from the beginning of the process (SCCS opinion, CMR classification, etc.) is crucial.
Several tools support this approach: subscriptions to regulatory databases (like Cosmed regulatory watch), participation in professional networks, and the integration of regulatory expertise from the design stage. Using "globally accepted" ingredients when available also helps secure launches and limit costly reformulations.

Beyond cosmetic regulations, one must also juggle environmental regulations, which primarily aim to eliminate greenwashing and improve transparency. Indeed, increasing sustainability requirements push formulators to integrate eco-design criteria: safety, effectiveness, but also biodegradability, transparency, and ethics. This is the essence of the "clean by design" approach: selecting traceable, responsible raw materials and packaging that comply with regulatory and consumer expectations. Among the most impactful in terms of sourcing are CITES, Nagoya, or the recent European anti-deforestation regulation or Packaging and Packaging Waste Regulation (PPWR)

Conclusion

In an environment marked by the rise of trade barriers and divergent regulations, cosmetic brands must rethink their models. Agility, regulatory monitoring, cross-functional collaboration, and resilient sourcing strategies are essential to ensure compliance and performance. Integrating these constraints from the design phase allows for risk reduction while transforming challenges into opportunities for sustainable innovation.