Question about starting a cosmetic line

Hi everyone,

I have a question about starting a new cosmetic production line (from home, for starter). Do I need to be cleared by HDA, FDA or any other organizations if Iam planning to sell online. I do line in CA, US.

Cheers!

Comments

  • MicroformulationMicroformulation Member, Professional Chemist
    Honestly, under cGMP standards you should have a separate space for Cosmetic manufacturing, to start. I would recommend using a manufacturer and dedicating my time to brand management. A Cosmetic Manufacturing Facility and a Cosmetic Line are very different Business models and it is not sustainable to do both over time.



    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • Honestly, under cGMP standards you should have a separate space for Cosmetic manufacturing, to start. I would recommend using a manufacturer and dedicating my time to brand management. A Cosmetic Manufacturing Facility and a Cosmetic Line are very different Business models and it is not sustainable to do both over time.


    Agree 100%. We started as a brand manufacturing our own products, and within a short time we were doing 80-90% OEM/Private Label. Our own brand suffered as a result.

    If we were to do it again, a clear decision would be made. Do we want a production facility, or our own brand? Make the decision. Then stick to it. 
    Dr. Mike Thair
    Cofounder & Chief Formulator
    Indochine Natural
  • PerryPerry Administrator, Professional Chemist
    I agree. If you want to start a beauty brand, work with a contract manufacturer. You'll need to focus your time on marketing and sales to be successful.
  • Yes I agree with Micro and Perry although it sounds like you want to produce it yourself. Are you a chemist?
    Dr. Catherine Pratt
    (B.Sc with HONS I , Ph.D Analytical/Organic Chem and Microbiology), Cosmetic Chemistry IPCS)
  • MicroformulationMicroformulation Member, Professional Chemist
    Many lines will believe that Manufacturing themselves is the way to get into the Market. It is really a mistake in the long run.
    • If you do not have the assets to send the project to a manufacturer, this speaks to your Business Model and Plan. If you are underfunded here, it is my experience that you are under-funded in these areas. START-UPS FAIL WHEN NOT PROPERLY FUNDED.
    • As an emerging line, one of the tasks you will be doing is developing contacts and determining vendors who can meet your need.  You are missing this opportunity.
    • Manufacturing is not as simple of an evolution that many believe. Remember, if you manufacture, you have the potential to be visited by the FDA. The FDA will not judge you as a small manufacturer but on the same level as any manufacturer in this group. Can you withstand an inspection?
    • Manufacturing themselves is always proposed to me by a line as a way to make money "until we can afford to use a manufacturer." I have seen this backfire. In the long run, your goal is to grow sales, thus increasing the manufacturing. Say you blow-up. It is usually about 60 days at best for you to establish a relationship with a CM and get manufacturing. This assumes that you have a perfect, validated Formula with mainstream Cosmetic Wholesalers listed and the testing performed. In the end, you deal with out of stocks and back-ordered product early on in your Sales cycle. Not having product for 30-60 days will usually be a line killer at this point.
    Look at it as a Project Manager. Emerging lines have "more time than money" and that is your strength early on. However, the goal of a line is to grow to the point where you "have more money than time."  TIME is your strength at first. Don't waste it on manufacturing yourself. Brand Management is key. There will likely be legions of people selling similar products. There will NOT be someone with your Marketing story.
    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • Good piece #Microformulation.
    Dr. Catherine Pratt
    (B.Sc with HONS I , Ph.D Analytical/Organic Chem and Microbiology), Cosmetic Chemistry IPCS)
  • Until you are making 6 figures the FDA will not know you exist! Can you start with a pilot study? Then you can see what are the best sellers, which areas eg Harrods or a local market.
    I would just concentrate on the formula & how it is behaving first. This way you can pick out the ingredients that are doing something or on trend. Also the costs of making it, stability, preservative 
    I start back work tomorrow so no Xmas for me LOL.. its never ending!!  
    BEST Dr Catherine Pratt 

    ps if you go straight to a manufacturer they will own the formula & if you have any disputes or just want to get away from them and Choose another one, they have the rights to own it &  you will have to buy it back of them in the vicinity of. A $5000 or more.
     luckily Dr Pratt’s does not get into that ok once we finish everything and you are happy with it, then you can take the formula  to the manufacturer and make sure they they use the formula properly. 
    Dr. Catherine Pratt
    (B.Sc with HONS I , Ph.D Analytical/Organic Chem and Microbiology), Cosmetic Chemistry IPCS)
  • MicroformulationMicroformulation Member, Professional Chemist
    edited December 2018
    Until you are making 6 figures the FDA will not know you exist!

    As a US-based Formulator, I deal with the US Regs on a daily basis.

    Incorrect. If you peruse the FDA Enforcement Letters, lines of any size can face enforcement. They have inspected small manufacturers. While a larger company will face more scrutiny, they become large companies in part due to good regulatory assurance.

    In the long run, net sales do not affect enforcement.

    Pilot studies of these "unique" ingredients are less likely if the claim or benefit is a Drug claim, as a "bioavailable" active (if this is truly accomplished) would be.
    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • OK maybe a pilot study then..LOL you guys are so different to aussies
    Dr. Catherine Pratt
    (B.Sc with HONS I , Ph.D Analytical/Organic Chem and Microbiology), Cosmetic Chemistry IPCS)
  • deannaji said:
    Hi everyone,

    I have a question about starting a new cosmetic production line (from home, for starter). Do I need to be cleared by HDA, FDA or any other organizations if Iam planning to sell online. I do line in CA, US.

    Cheers!

    It can be done, but you need to be realistic and have a plan. I started out working on a few recipes using a corner in the premises of another business. When things started to look promising I took over the premises, hired staff, and then worked on the GMP, and product registration with the cosmetics authorities, etc etc.

    As things progressed, we then moved country where we had better international air and sea shipping facilities. And again built a premises that is GMP and Halal Certified.

    In my experience, starting at home is a good starting place. If you see potential, then you MUST be prepared to invest in proper GMP facilities and the required staff. Yes, GMP id expensive, and you need the staff. NEVER expand too much without the GMP facilities. If you do, it can turn into a disaster if you are caught. 

    Follow your dreams. I did, and you can read about it here: https://indochinenatural.com/the-indochine-natural-brand-story/

    Dr. Mike Thair
    Cofounder & Chief Formulator
    Indochine Natural
  • MicroformulationMicroformulation Member, Professional Chemist
    edited December 2018
    I would have to say that the home is great for experimenting, but I would not manufacture and sell out of the home IN THE US!! Many States will set requirements regarding the facility and licensing.


    Please note that the general consensus of the FDA Auditors I have spoken with take the stance that anyone who manufactures a Cosmetic product, regardless of size must comply with the cGMP Guidelines; https://www.fda.gov/cosmetics/guidanceregulation/guidancedocuments/ucm2005190.htm

    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
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