Zhang Jing

MZ Toutiao Media Guangzhou Co.,Ltd.,China

On April 10,2023,the Shanghai Municipal Medical Products Administration issued a notice on the public consultation of the “Shanghai Pudong New Area General Cosmetics On-site Personalized Service Review Rules (for trial implementation)” (draft for comment),marking the public call for comments from April 3 to May 2,2023.This is another effective regulatory measure following the Shanghai Pudong New Area in June 2022 and the National Medical Products Administration in November to further explore a viable mode for personalized cosmetic services.

Encourage personalized services and ensure full traceability

The “Shanghai Pudong New Area General Cosmetics On-site Personalized Service Review Rules (for Trial Implementation)” (Draft for Comments) (hereafter referred to as the Draft)contains a total of 8 chapters and 34 articles,regulating the on-site personalized service for general cosmetics in the city’s Pudong New Area from various aspects such as on-site personalized service licensing,product filing management,institutions,personnel,quality assurance and control.According to the Draft,the so-called on-site personalized service for cosmetics means that the cosmetic filer and the domestic responsible person,provides onsite personalized services according to the individual needs of consumers on general cosmetics (excluding children’s cosmetics,eye care cosmetics,cosmetics using new raw materials,etc.) in a special area set up inside the business premises,with on-site dispensing and packaging services and direct contact with the cosmetic contents.In addition,Article 4 shows that cosmetic companies are encouraged to use digital,mechanized,automated and other advanced technological methods to carry out onsite personalized cosmetic services to ensure that the service operation is standardized and traceable throughout.

In terms of institutions and personnel,the Draft also requires that enterprises should be equipped with quality management personnel,operators and inspectors to match the on-site personalized service cosmetics,develop and implement annual training plans,carry out pre-employment and in-service cosmetics-related legal knowledge,professional knowledge and operational skills training,and establish training files.Quality management personnel and operators are not allowed to hold concurrent posts.

It is worth noting that this is not the first time that Shanghai has issued a notice on cosmetic personalization services.As early as June 2022,the“Shanghai Pudong New Area Cosmetics Industry Innovation Development Regulations (Draft)”mentioned that it would encourage precise research and development of cosmetics for “personalized needs,” and made plans for the personalized cosmetics service and its management in Shanghai.

Five provinces and cities launch pilots to explore new modes of cosmetics

In November 2022,in order to implement the requirements of the administrative and service reform,to explore feasible modes and effective regulatory measures for personalized cosmetic services,to form replicable and transferable experiences and practices,to better meet consumer demand,and to promote the high-quality development of China’s cosmetic brands and industries,the official website of National Medical Products Administration (NMPA) published the “Notice of the Department of Comprehensive Affairs,Planning,and Finance Affairs of NMPA on the Piloting of Personalized Cosmetics Services.”The pilot has begun in November 2022 for a period of one year,and the pilot area includes Beijing,Shanghai,Zhejiang,Shandong,and Guangdong Province,the medical products administration of each pilot province (municipal city) can select one to three registrants for record as personalized service pilot enterprises.The pilot work focuses on exploring personalized service modes,giving full play to the role of the industry as a market player,and encouraging pilot enterprises to explore skin testing,product tracking,personalized skin care service programs and other aspects in the fields of makeup,skin care,and other general cosmetics.

In addition,the pilots are actively exploring effective regulatory measures for personalized service modes.The pilot provincial (municipal city) medical products administrations are encouraged to innovate regulatory modes under the existing regulatory framework for cosmetics,and to optimize regulatory approaches in the areas of product filing,testing,sample retention,and sales management.The administrations are supposed to conduct research and develop normative documents related to personalized services and,through pilot projects,carry out reasonable optimization in line with the relevant regulatory requirements for cosmetic product filing,production supervision,and risk monitoring,in order to ensure the quality and safety of cosmetics while meeting the personalized needs of consumers with cosmetics.

From upstream to downstream,multiple companies step up to the customization track

In recent years,with the popularity of efficacious ingredients,more and more consumers are demanding more refined skincare solutions.Along with the rapid growth of skincare products,customized skincare is also emerging.Skincare products that are tailored to consumers’ skin conditions and individual needs can be more targeted to address consumers’ skin concerns and are therefore increasingly popular with today’s consumers.According to data released by market research agencies,the next-generation customized beauty market has reached 265 billion yuan in 2019 and is set to exceed 500 billion yuan by 2028.In the future when customized cosmetics are prevalent,the number of customers will grow exponentially.

Consumer recognition and market growth,coupled with supportive policies from the NMPA and local governments,have made the custom cosmetic industry more and more popular,with more and more companies from upstream to downstream stepping up to the customized cosmetics circuit.

Veminsyn,founded in 2021 with a funding of over a hundred million yuan,is a well-known bioactive materials developer in the industry,and also provides a technology platform for brands to develop “one-stop” customized raw material services and jointly explore the path to customized development of new raw materials.In addition,Cosmax and CJ ONSTYLE,the world’s leading cosmetics research and development companies,are the first to launch WAKE ME,a customized shampoo and hair conditioner brand.Cosmax Group Chairman Lee Keng Soo said in a public interview that the customized cosmetics market would be the next industry trend.Representative director Lee Beng-yeon even said bluntly that in 2023,Cosmax will deepen its product customization business and the scope of customization will be expanded from shampoo to skincare and makeup cosmetics.

Zimmer Lab,a scalp care brand founded in 2020,focuses on skin-tailoring,providing users with differentiated products by customizing them to suit different types of scalp conditions and user needs.Fragranced personal care brand Plustwo features products such as a lightly customized shampoo that uses split ampoule technology.In February 2022,AmorePacific launched Custom Me,a new 1:1 lifestyle beauty customization brand designed for sensitive skin,is receiving attention ......

In addition,Unilever,Shiseido,L’Oréal,Yue-Sai,EasyCare,Chando,Biohyalux,and many other beauty companies have also launched personalized customized products.Customized skincare brands ICO said that the reform of regulations is good for the development of the industry and enterprises,and that customized cosmetics is a product of consumer upgrading.Global big brands have joined in the cultivation of this emerging land,but many domestic brands are still in a wait-and-see mentality,mainly because the regulatory and compliance level remains to be innovated and broken through.The upgrade in regulations is a great encouragement to companies already walking this path,and the future outlook for the cosmetics sector is very positive.

In the era of exclusive customization,the future of the packaging industry is moving in the direction of personalized customization and posing higher requirements for product quality.

More concept than substance,“one recipe for one person” remains a challenge

While the cosmetics customization market may seem vast,it is not a simple thing to achieve.Firstly,the process of personalizing cosmetics is complex and the safety and hygiene of the formula is not easily guaranteed.Secondly,most customized cosmetics have a long working cycle,which is obviously not realistic for consumers.Furthermore,the price of personalized cosmetics is relatively high compared to regular cosmetics.The celebrity Yang Rong once exposed on a entertainment show that the price of her customized face cream exceeded ten thousand yuan,causing a heated discussion among netizens.Therefore,only a small number of consumers can afford to have their cosmetics customized.The most noteworthy thing is that the “customized cosmetics”launched by many beauty companies today are actually more of a concept than substance,and not really “one recipe for one person” or “one product for one person.”

Search for “customized cosmetics” on major e-commerce platforms,and you will find that although there are many personalized customized cosmetics on the result list,many businesses are producing and selling unrecorded cosmetics under the guise of “customization.” A reporter randomly asked a beauty shop how to customize products,and received the response that the “one recipe for one person” was based on the skin condition of users’selfies without makeup.However,when the reporter asked about the manufacturer of the product being inquired,it turned out that the company had been notified by NMPA for adding banned raw materials.

Customized cosmetics are currently facing problems such as high corporate costs,high costs of trial and error in industry operations,and market and consumer education.But brands have been persistent in doing customized skincare because the future of this track is promising.A researcher at a factory in Guangzhou said that the “customized cosmetic products” launched by many brands nowadays are still a pseudo-concept,and are not tailored to individuals,but just divide the skin into several types and arrange them through a large number of SKUs,which can only be called segmented products at best.

All in all,although the original intention of“customized cosmetics” was good,it still faces many insurmountable gaps at present.However,as the Draft consultation and regulations about pilot work take hold,the development of customized cosmetic services in the country will be accelerated.