So we can have a direct comparison between the registration process in UAE and that in the EU as an example.
We will first talk about a specific product cycle (for example hair care product) and what are the steps and duration the company take to develop it and then launch it in the market, at the same time study in details what are the regulatory process that this product needs to first comply with before being able to access the market.
I think addressing the above point would be very focused, linked to innovation and the very fast pace of continuous changes taking place in products either being upgraded or newly launched and also deep dive into the regulatory process by the regulators where we would investigate the process, it’s objective, it’s effectiveness in meeting this objective and how it affects the accessibility of products into the market.
Cosmetics usually follow a sequence of minor and major upgrades:
A) Every year there is always a formula upgrade (this usually includes a change in formulation, or active ingredient characteristics or addressing seasonal consumer need). (Can we call this the incremental innovation? Even if this incremental innovation is carried out by cosmetic firm as part of their annual plan /strategic plan regardless any intention to comply with the regulation? )
B) Every 5 years there is usually a BIG update that includes revamping of the product/brand as a whole; could include introduction of new variants, product delivery system, benefits and claims, major changes in branding, completely new formulations etc. . . (Can we call this the radical innovation? )
To perform a product upgrade, below is how the cycle looks like; as mentioned earlier the cycle usually happens in parallel not one after the other, in other words, a company would start planning in 2016 the product they are going to launch in 2021 (major upgrade) at the same time the company is also planning the smaller upgrades that will happen before that such as those upgrades happening in 2017, 2018, 2019 and 2020.
The cycle looks as follows:
It is important to note that companies want to work on a broad scale and here broad scale is not considered as 1 market or even a cluster of markets but companies want to launch a product for all the countries in a continent or more wherever the consumer profile and needs are similar.
Companies accordingly cluster the markets depending on market dynamics and economy (developed vs. developing), consumer preferences (likes and dislikes) and geography (supply chain and sourcing). Popular regions/clusters are MEA (Middle East & Africa), Europe, North America (US & Canada), Latin America and Asia, this clustering makes sense from a business stand point and usually the manufacturing facility is serving a full region or more. Accordingly being able to launch this new formula in a broad region as the ones mentioned above means that the product should have all the needed approvals to access the market at the same time (to save cost and produce on a large scale), this is why the registration procedure and specifically duration is one of the biggest challenges a company face in launching new innovations and products into a market.
More importantly is looking into the process and the procedure of the registration itself, and the duration it takes to prepare the documentation needed as well as the time needed by the authorities to review the documents submitted and give the go ahead.
This could seem as a straight forward process but doing and repeating this process for the number of new products launched every year is definitely a challenge; every year there are around 50,000 new cosmetic products registered in UAE.
For instance it takes in UAE 5 months minimum to launch a new product (starting from getting the documents needed with the legalization, attestation etc. as well as the time needed to review the product by the authority) while this initiative as a whole would not be staying on the market shelf for more than 12 months where the new next update will be coming shortly after.
Looking into the above we can clearly conclude that there is a misfit between the product innovation/marketing/launching cycle and the regulatory approval/registration cycle as we look into and investigate all the aspects at both sides such as changes that takes place in products during the minor and major upgrades that happen ever 1 and 5 years respectively as well as looking into the process from the regulator’s side including the requirements, assessment performed and effectiveness of the process in ensuring consumer safety, we definitely also need to have a clear comparison between the regulatory process in the GCC and the EU.
What we need to do now is focus the efforts and research on 2 things
1) Company process (R&D , manufacturing and marketing) to launch new product in specific region (GCC as an example) and point out in details the steps it takes and have a case study on one of the new launches as an example
2) At the same time we would need to look into the regulatory approval process (registration) that this product has to go through before it is able to access the market
This would entail several other key questions:
1) Is this regulatory process effective in ensuring consumer safety?
2) Does this regulatory process ensure that only compliant/safe products access the market?
3) What is the magnitude of complexity that this process entails on the manufacturers and importers?
4) What is the effect of this process on the products available in the market (price, timing of market access versus other markets that do not have a pre-market registration process?
5) What are the alternative regulatory processes enforced in other countries (effective and ineffective models)
6) Where does the current process in UAE/GCC stand versus what is considered as global best practice?
The questions should then be evolving around the mandatory regulatory compliance process that a firm should follow before being able to access market:
RQ1: Is the current Cosmetics pre-approval process in UAE effective in ensuring consumer safety?
RQ2: Does the current Cosmetics pre-approval process in UAE hinders industry innovation and prolongs time to market access versus global markets?
RQ3: Is the current regulatory pre-approval process in line with global best practice?
Let me know what you think of these 3 questions?