How to avoid a cosmetic product recall
Another day, another product recall. Or, at least, that is how it feels reading the beauty trade press, or scrolling through email alerts from different countries’ safety authorities. Sunscreen has come under particular scrutiny, recently, with Medik8 recently recalling five batches of three SPF50+ sunscreens in Australia over concerns that the products did not meet the promised level of protection, according to the country’s Therapeutic Goods Administration (TGA).
Separation problems dogged Bondi Sands this year, with the UK’s Office for Product Safety and Standards issuing a recall notice for the brand’s Zinc Mineral Sunscreen SPF50+ Body Lotion and Face Lotion products. The authority explained that “the product presents a risk to health because certain batches have shown signs of separation and uneven texture – if the ingredients are not properly mixed, the SPF rating may be variable and place consumers at risk of sunburn.”
Meanwhile, Hello Sunday’s The One For Your Eyes Mineral Eye Cream SPF 50 underwent a voluntary recall in the UK over concerns that it does not give the full level of protection stated, with Hello Sunday announcing the move via its website.
But sunscreen makers have not been the only cosmetic and personal care players to carry the shame – and cost – of a recall. Last year, Neutrogena voluntarily recalled its Makeup Remover Ultra-Soft Cleansing Towelettes in four US states due to possible bacterial contamination. This followed an internal investigation in which some items tested positive for Pluralibacter gergoviae, a bacterium resistant to preservatives typically found in cosmetics. Possible bacterial contamination also spurred the voluntary recall of 1,068 units of Tec Italy Shampoo Totale in the USA by Henkel’s Mexico branch, because the product had the potential to be contaminated with Klebsiella oxytoca, which can cause infections in humans.
Then there are cautionary tales about keeping abreast of regulatory requirements across different markets. In the UK, in December, Markwins Beauty Brands-owned Wet n Wild’s Proline Felt Tip Eyeliner was recalled as a result of a non-conformity identified during a product regulatory check. According to the notice, the product presented a “serious chemical risk” as it was found to have a concentration level of 11.5% Carbon Black (nano) color pigment, which exceeds the maximum permitted concentration in cosmetic products (10%), thereby failing to meet the requirements of Regulation (EC) 1223/2009 (The Cosmetics Regulation).
Even Rihanna’s brands have tripped up, with the musician and entrepreneur’s Kiss, RiRi and Rogue fragrances sold by Savers Health and Beauty stores found to contain butylphenyl methylpropional (BMHCA/lilial) and/or hydroxyisohexyl 3-cyclohexene carboxaldehyde, both prohibited in cosmetic products under Regulation (EC) 1223/2009.
With pressure on brands for quick-to-market formulations, complex global supply chains and an ever-changing regulatory landscape, beauty product makers have to keep on their toes to avoid recalls. Product Lifecycle Management (PLM) software is a tool that centralizes, organizes, and tracks all stages of a product’s lifecycle. PLM allows you to compare cosmetic ingredients, manage alternative raw materials, perform cost simulations, and make sure that the raw materials selected meet the project’s regulatory and environmental constraints, so you can ensure your preservation system is as sound as possible.
During the formulation phase – when you are meeting the marketing brief requirements while simultaneously complying with regulatory constraints – Coptis Lab PLM simplifies formulators’ work via its database and automation capabilities, managing blacklisted substances and issuing regulatory alerts to check whether the proposed formula is compliant with target markets. Coptis Reg, a recently-launched regulatory database that supports Coptis Lab PLM, offers regulatory data on a hundred countries and more than 15,000 substances. This reduces the risk of errors and avoids a Wet n Wild-style regulatory ‘oops.’
And, when it comes to quality control, PLM software tracks and documents every test, guaranteeing complete traceability for users. Real-time alerts facilitate the implementation of immediate corrections to improve the fluidity of the approval process, while PLM solutions offer the ability to create test scheduling calendars.
Of course, even with all the most stringent measures in place, recalls are still a reality for most companies – and here transparency and communication are your best friends. By proactively sharing your voluntary recalls in spaces where consumers frequent, like your website, or Instagram, you are reaching as many people who could be negatively affected as possible. This has the dual benefit of minimizing harm and restoring confidence, and can be aided by better coordination and communication across various departments involved in product development. PLM software fosters real-time collaboration among formulation, quality, regulatory affairs, and marketing teams, connecting them all to a common platform that enables everyone to access up-to-date information and track project progress.
Some companies have even managed to turn a recall into an advantage. When Loli noticed some visual sedimentation in a quality assurance retain of one of its micellar waters, the ethical beauty brand made the decision to issue a recall, as the product did not meet its quality standard. The brand salvaged a make-or-break moment by contacting every single customer and refunding them, transforming the moment into a loyalty-building experience.
Recall experts note that while recalls are not always avoidable, what defines a brand is not whether a recall happens, but how effectively it is handled – and that companies who are both prepared and candid are more likely to preserve consumer safety and their brand reputation.
Stringency throughout product development, strong cross-team communication and a philosophy/reputation for transparency all serve to reduce the chance of a recall and provide you with the tools to minimize the damage in the event of a recall scenario – or even turn the situation into a win! And Coptis Lab PLM can help.
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