
There’s a global cosmetics regulator. It has met twenty times. Ask any indie founder you know if they’ve heard of it.
It’s called ICCR, the International Cooperation on Cosmetics Regulation. Regulators from Brazil, Canada, the EU, Japan, Korea, the UK, the US and a few others have been meeting once a year since 2007. The twentieth meeting was in Tokyo this July. ANVISA sits at that table. So does Health Canada. Nineteen years of harmonization talks, and a small brand still can’t ship the same cream to four markets with one file.
I bring it up because every few months someone in this industry says the obvious thing out loud, and I’ve said it myself. Beauty is a global business run by local rulebooks. E-commerce platforms pop up faster than anyone can police them. So why not one global body for cosmetics, a FIFA for beauty, that sets the rules for everyone? The answer is that the polite version already exists and has changed almost nothing, and the strong version would make things worse.
Why has ICCR changed so little? Because it runs on consensus and every decision has to fit inside each member’s existing law. It aligns vocabulary and test methods. It doesn’t produce anything you can hand to an agency.
And a stronger version, a real FIFA with teeth, would be worse. Today L’Oréal has to lobby Brussels, the FDA, ANVISA and the NMPA separately. Give the industry one global body and you’ve handed the biggest players a single door. One door, one lock. FIFA is the perfect example of what happens when a world body answers to nobody. And that’s before you get to sovereignty. No country is going to let a foreign committee decide what goes on its citizens’ skin. Not China, not the US, not Brazil.
So the talking shop exists, the strong cure is wrong, and the problem is still sitting there. Let me lay it out, because it’s worse than people think.
L’Oréal was founded in 1909. Coty in 1904. That was a world where you could get on a boat to New York without a passport, and the result of that openness was beauty becoming one of the biggest sectors of the modern economy. Fast forward to what was supposed to be the most connected generation in history, and a small brand can’t go global because the cost of reading, let alone meeting, four different regulatory codes is impossible for a company selling a few hundred units a month. And easily absorbed by a conglomerate with a regulatory affairs floor.
Compliance is a fixed cost. A fixed cost is a regressive tax. That’s the whole mechanism.
Want to see it happening in real time? Since August 12 this year, under the EU’s new packaging regulation, anyone selling packaged goods into an EU country where they aren’t established has to appoint an authorized representative in that country. One per country, so a brand shipping across the bloc is looking at up to 27. Plus a registration in each national producer register, each with its own portal, its own annual report and, in many of them, a minimum fee whether you ship 100 units or 100,000. The per-kilo waste fee itself is fair, you pay for what you put on the market. It’s the 27 doors around it that aren’t. A conglomerate walks through all of them once, with a team it already has. A brand selling 100 units a month does it alone, or stops shipping. Plenty already have. That’s the video I watched yesterday.
And here’s the detail that tells you who the system is built for. Brussels knows this is a mess. The Commission proposed suspending the representative rule until 2035. Member states stalled it in June. Parliament is now negotiating a narrower exemption for companies under 49 staff. But every version of the relief on the table is written for EU-based companies. A Canadian or Brazilian indie gets nothing. The people who wrote the rule are fixing it for their own small brands and leaving everyone else’s outside.
Nobody designed this, and it doesn’t matter. Every fix gets negotiated with the companies that can afford to be in the room, because those are the companies that can threaten job losses and lower tax collection, so every fix ends up shaped like them. Brands get built to one spec now: reach the size where a conglomerate buys you. Lasting isn’t the plan. And it’s happening in almost every industry, beauty just happens to be the one I work in.
Now. What would actually work?
Copy pharma, not football.
Pharma solved the solvable version of this problem with something called ICH. No country gave up its authority. The big regulators just agreed on one dossier format, the CTD, so a company builds its file once and each agency still says yes or no on its own. Same file, local stamp. ICH launched in 1990 and had the CTD by 2000. ICCR is nineteen years in with nothing comparable. Beauty needs exactly that, and three pieces would get us there. None of them is new. All three exist somewhere, just never together.
First, one Product Information File that ANVISA, Brussels, the FDA and the NMPA all accept as the starting document. ASEAN proved this works inside a bloc: ten countries, one harmonized file format since 2008, built on the EU model. ASEAN also proved the trap, because they never got mutual recognition working and companies still notify in every country separately. So the treaty needs one line ASEAN never enforced: the file is accepted as filed. Countries keep their veto. They just stop demanding different paperwork for the same cream.
Second, size tiers written into the agreement itself, not left to each country’s mood. The US already has one. Under MoCRA, a brand doing under a million dollars a year in US cosmetic sales is exempt from GMP rules, facility registration and product listing. Europe has no equivalent. That’s the mood problem in one sentence. The global version: under 50,000 units a year, you self-certify against ISO 22716 and file a simplified safety assessment. For packaging, one registration covers the whole bloc, one representative instead of 27, no minimum fee below the threshold, and foreign brands get it on the same terms as the ones born inside the border. Keep the per-kilo waste fee exactly as it is. That part already works.
Third, the compliance tooling goes public. A free, open ingredient database with the limits for every member market, and templated dossiers a chemist can fill in without a lawyer. Paid for by a levy on sales above half a billion a year, so the big brands fund the ladder the small ones climb. And the committees that write the technical rules, the ingredient lists, the preservative limits, the packaging thresholds, get reserved seats for brands under the threshold and a published meetings register, because that’s where capture actually happens. Nobody at a conglomerate cares who the president is. They care who drafts the allowed-substances table.
And then the part I still want. A real Beauty Olympics. WorldSkills already sends national teams of hairdressers and beauty therapists to compete for medals, about 1,300 competitors from 60 countries in Lyon in 2024. So countries will put a flag on a technician under 23. Nobody has put a flag on a formulator or a brand. That’s the gap. A world cup for formulation, packaging, brand, with national teams. Countries with no R&D budget get a podium to chase, which means training chemists, which means GDP, which means a Ghanaian shea brand or a Colombian botanicals house competing on the same stage as Paris. No country will surrender power to join a treaty. Plenty will sign to win a medal.
Give small brands one file, a rulebook sized to their volume, free tools and a stage. The pieces are already lying around. Somebody just has to bolt them together, and it won’t be the people who benefit from them staying apart.
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