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Overview

Ready to launch your own beauty or skincare brand in 2024? Join our exclusive webinar where we break down the essential steps to build a successful brand in this competitive industry.

In this session, Alex from Pietra’s production and sourcing team will guide you through the intricacies of sourcing, developing, and launching beauty and skincare products. We’ll cover everything from working with suppliers to navigating the complexities of product certifications.

Special guest Dr. Rima Patel from Glow Comply will dive into the legal requirements you need to know, including the new MOCRA certification mandates for beauty and skincare products in the U.S. as of 2024. Learn how to ensure your products meet all necessary regulations to avoid costly setbacks.

Pietra makes it easy to navigate this journey. With Pietra, finding the perfect factory for your beauty and skincare brand is a seamless process. Pietra connects you with top-notch factories that align with your brand’s values and requirements. Additionally, Pietra offers a members-only 3PL service, comprehensive sales and marketing tools, Shopify integration, and more to help you start and grow your beauty brand.

Workshop Recording

Transcript

Sourcing on Pietra with Alex Beck

Hey, everyone. I hope you're having a nice day. I'm just gonna give everyone a few minutes here to join and then we'll get started. While we wait for everyone to join here, I figured I'd take a couple of minutes to introduce myself and tee up today's meeting a little bit.

My name is Alex. I head up our production and sourcing team here at Pietra. My background is in product and brand development. Before my time at Pietra, I spent time on the brand side developing products and assisting with brand development et cetera. Since joining Pietra a little over two years ago, I've, you know, headed up our production and sourcing team over here helping our top clients execute, you know, their sourcing sprints and production runs.

Today we're gonna focus on beauty and skincare because it truly is a beast of its own. It's one of the most complex product categories out there. However, there are some workarounds and fun ways that you can bring a product to life without needing to, hit those high minimum order quantities or those high development fees that are sometimes associated with launching a beauty or skincare brand.

Today we're going to have a special webinar format. I'm going to spend the 1st 15 minutes or so walking through how to use the platform to source beauty and skin care products and suppliers. Then I'm going to pass it over and invite Doctor Rima Patel up to co-host with me. She works for a company called Glow Comply which essentially acts as an agency helping brands get their products set up for Mocra certification either on the manufacturer level or on the brand level.

As of July 1st of this year, just a few weeks ago, the United States has started to requiring Mocra certification for all beauty and skincare products. Again, I'll let Doctor Patel guide that portion of the meeting and we'll save time do a Q and A at the end, so feel free to drop any questions that you might have in our chat and myself and Dr Patel will do our best to answer all of them.

Well, let's go ahead and get started.

I'll start by giving everyone a walk through of Pietra. But before we dive in, there are a couple bigger terms that I'll be using during today's meeting. One of course, you'll hear the word MOCRA. It's a certification that's now required as of earlier this month for beauty and skincare products.

Another acronym that you'll hear me use is MOQ. MOQ stands for minimum order quantity. If you're not familiar with the term, an MOQ is a required minimum order quantity that a supplier or manufacturer sets for a certain product. These are largely determined by the raw materials and labor that go into producing the product. At the end of the day, the manufacturer needs to be profitable. so they're going to look at the unit economics and say, “Ok, Alex wants to order some lip glosses, we know it's gonna take X amount of labor and X amount of raw materials to make those lip glosses. Her minimum order quantity for that product needs to be Y units.”

In addition to this, you'll also hear me use the term private label. Private label, if you're not familiar with the term, essentially is a product that is already manufactured by the supplier and is cleared to go to market. It's a huge win, especially in the beauty and skincare space, because it means that the product has already undergone all of the required testing, whether that's stabilization testing, vegan claim certification, organic claim certification, clean claims, etc.. This means that the burden is no longer on you to execute those tests or certification for a product you're developing and, instead, the supplier has already made the product and tested + cleared it. In turn, this means that the product is available for purchase at lower quantities. With private label you can sometimes change the product a little bit (ie. packaging or fragrance).

Now that we've gone through those couple terms. I'm going to start sharing my screen. I am logged into my Pietra account here and this is what we call the Pietra home base. It’s the home based starting point for anything that you would want to do in Pietra. You can start by creating custom projects, custom packaging, maybe you're at the beginning stages of your brand and you actually need help hiring a freelancer to do your logo design or make a brand guideline.

To get started sourcing skincare and beauty on Pietra, the first thing is to navigate to where it says sourcing and then scroll down. Here you can search by products.

As an example, let’s say you want to produce some sunscreen. You can use our search tool here to search for sunscreen and find factories who make sunscreen or SPF products. Here you can see suppliers that make sunscreen. Here's some with some really great private label options that the manufacturer has already produced. It's gone through clinical testing, it's certified as SPF 50 and other claims might be interested in. As you can see, they are available to purchase these directly at low MOQs. For example, let’s look at this SPF tinted powder, which is similar to what Supergoophas done - you can order just 200 units of it!

Alternatively, if you want to do something custom formulated from the ground up, such as a face oil. or maybe foundation that's a custom color range, I always suggest instead of browsing by product that you suggest or that you opt to browse by factories. These are all factories here that have the capability of producing face oils. You can click into them and read reviews or their references to past clients that they've worked with. So for example, with Genie Supply, you can see that they have clients who retail in Nordstrom TJ, Maxx Marshall's free people, Urban Outfitters and Ulta. Genie Supply would be a really amazing supplier if you're looking to do something in the skincare and beauty space! I have had a really positive experience working with them. I am happy to highlight a few more suppliers if any of you have requests for specific recommendations! Feel free to drop your question into the Q&A section.

So let's say, you know exactly what you want to make or maybe you have a really specific benchmark for what you want to do, for example you know that you wanna duplicate Rare Beauty’s best selling blush. If that's your situation, I suggest clicking this request custom project button. You can use the RFP button for products, packaging and even freelancers if you're looking for a designer or a web developer, etc. Essentially, this tool allows you to create a product proposal and send it to Pietra's network of manufacturers. This, in turn, means that instead of you needing to go through and browse and sift through all of our manufacturers that can make your product, your product brief instead is sent it to the suppliers and if the suppliers can take on your project or are interested in taking on your project, they will then send you a message.

Let’s do one together. For this example, let’s say the category is beauty. Let's say you want to make a custom tinted lip stain. Below is where you would add your product details. I always urge customers to add as much information as possible. The more direct you can be with the manufacturer about exactly what you're looking for, the easier it will be for them to understand exactly your request + provide a quote. For example, I would include things like your target MOQ so your minimum order quantity, your target retail price, colors, packaging, ingredients, and claims (such as vegan, Sephora Clean, dermatologist recommended). Next is where you add reference photos, list your target retail price and a link to a benchmark if you have one. Here you will see that there are two options to choose from, private label or custom. Generally, private label can be produced at an MOQ of 100-200 units per product while custom requires multiples of thousands. In regards to packaging MOQs, completely custom packaging necessitates a higher MOQ while stock packaging with a simple print or label can usually be achieved at low MOQs.

Moving on, looking at the timeline selection section, it’s important to consider the lead time. Private label can generally be produced in about 30 days because, technically, it’s already manufactured. On the contrary, custom formulation and development can take anywhere from 6-9 months, or even 9-12 months depending on the testing you require. This long lead time is largely driven by stability testing. In order to safeguard your brand, stability testing should be conducted! During stability testing, the manufacturer essentially takes your product and puts it your component and then leaves it to sit for several months to make sure that the formula does not split or separate (ie a gloopy sunscreen).

Now that the form has been completed, if you are a Full-Service member, you can check mark this box that says “get concierge help”. When you check-mark that box, the request goes to our suppliers, but it also notifies my team on the sourcing and production side and lets us know that a full service member is looking for some extra help. We will then review your brief and then send you a message through our chat feature to help point you in the right direction. After submitting, over the next 24 or 48 hours, you will start to receive messages in your inbox from suppliers.

Here’s your Pietra inbox, I always like to recommend to customers to use this tag feature. It makes it easy to stay organized, especially if you were looking to produce multiple products. For example, let's say you're looking to do a skincare line with an oil, a cleanser and a lotion that are all coming from different manufacturers. I would tag them here to keep them organized! This is also where your invoicing and order history will live.

In case you need some extra sourcing assistance, I’ll show you how to message our sourcing specialists! Start by clicking into any product category and then select this button at the top that says “talk to a specialist”. This prompts our chat feature which has a few automated questions that help direct your inquiry to the right team member. Once you get to the end of the flow, the request actually comes directly to my team. My team will then review your inquiry and help point you in the right direction!

Pietra Platform Q&A

Question: Once you select a formula, how do you coordinate packaging and box components to be assembled and filled? What if you want to use an outside provider for packaging that's different from the formula provider?

Answer: That's an excellent question! To your point, you don't have to source the components from the skin care or beauty manufacturer. Of course, it's easier if you do, but if you are looking for something more custom and unique and the skin care or beauty manufacturer doesn't have that style bottle or pump that you're looking for on hand, you can always look externally for a component supplier. We do have components manufacturers on platform such as JCG & Shine Ray.


Question: If I want to develop a product,, or skin care line with the goal of getting into Sephora, do I have to have custom formulation or can I do private labeling?

Answer: That’s a tough question as I'm not a Sephora buyer. Generally speaking though, I would say that buyers want something that's unique & custom, unless the brand is carried by a Powerhouse celebrity. That's generally the only way that you can get into a retailer like Sephora or Ulta without doing custom formulation.


Question: What is the typical shelf life of the products or are they dated with recommended use or expiration date?

Answer: Generally in the beauty and skincare space, they're not dated with a concrete expiration date. Instead, they're given a lot number, and an icon denoting the anticipated expiration date (ie 2M or 24M). The manufacturer will help guide you through this process.


Question: When we start a private label product, do companies or Piatra promote or advertise new brands?

Answer: We love to shout out our customers who are launching brands. If that's something you're doing. Just send us a message and we'd be happy to shout you out.


Question: Do the private label companies offer drop-shipping?

Answer: Our system is not set up for drop shipping. Instead, our system is set up for customers who want to build a scalable brand as opposed to just drop shipping private label products.

Regulatory Compliance with Dr. Patel (Glow Comply)

Hi there, my name is Rima Patel. I'm a physician by training and I work for a company called Glow Comply. Essentially, we help you be compliant with the new regulations that have been passed for beauty, skin care and personal care products in the United States.

Here's a brief overview of what MOCRA is. Essentially, it's the Modernization of Cosmetics Act. It's actually one of the first legislations passed nationally in the United States since 1938, so we're gonna start to see stricter enforcement. I do want to caveat that MOCRA does not supersede state regulations. So, we're starting to see California, Washington, Nevada, and New York actually have additional requirements and processes. As the year goes through, we're sort of seeing how the States are really pushing the regulations, so your products might have to be even further compliant than what MOCRA requires currently.

Here are the basic requirements of what MOCRA means: your manufacturing facility essentially has to be registered with the FDA. For your products, you as the brand have to register them with the FDA. You do have some leeway that once you launch into the market, you do have X allotted days (that are fluctuating) for when you need to be registered. If you're already on the market, you should have technically been complying by July 1st of this year. But they're giving you a little bit more room until December to make sure that you really have the requirements in. Next, we're gonna go over who the responsible person would be for your brand labeling requirements, and lastly we’ll go over inverse reporting.

The reason MOCRA is important is that if you don't actually get compliant and registered, let's say your product is shipping from overseas, for example, right? It can get held up at the ports. Let's say you're already on the shelves – you might have legal problems if someone ends up having some sort of reaction to your product that wasn't previously documented.

The first step of MOCRA is defining who the responsible person is. There's a lot of confusion around the legislation, but technically the responsible person is not just your manufacturer, it's whoever's name goes on the brand. So if I have my own skin care line called Rima, I essentially need to make sure that I also am certified as the responsible person and register my product with the FDA. And so what does that mean? Basically that means your product has to be listed. You have to have a system in place for people to report side effects, your label has to be compliant, and you need a record of the side effects that are reported (which the FDA can ask you for at any time).

Here are the basics of the brand, registration and product listing. Like I mentioned, if you're already on the market, the deadline was July 1st 2024. It's new and confusing, so they are giving a little bit more room if you are a larger size brand. If you're over $5 or $6 million in revenue, you really need to start to get all that stuff together now. First, there’s an annual update required for brands. Second, if you have a change in formula ingredients within 60 days, you really need to get that registered and have that change reflected with the FDA. Last, relating to the facility you choose: it's important if you're starting your brand from day zero that your facility is actually registered with the FDA.

What is the adverse event reporting? So, under the MOCRA guidelines, reports must be made within 15 days of someone having some sort of reaction. Here's the list of examples, and I've included a link if you really want to go through exactly which ones. But if anyone has any infection, hospitalization, death, or life threatening experience, it's really important to have that reported with the FDA. And you have to also make sure that for example, with social media, it kind of gets a little bit more tricky if someone goes on Tik Tok and is talking about all the side effects that have been caused by your product. It's probably in your best interest to just go ahead and register that side effect even though that might just be a one off thing.

So what are the new labeling requirements? The new labeling requirements now need you to have contact information for your adverse event reporting. Additionally, if your product is going through med spas or doctor offices, you need to have a professional use only labeling. If you're mainly like an Ecomm brand, then this part probably doesn't apply to you, but the contact information and adverse reporting does. And then if you were a perfume brand, it's very, very important that you have your fragrance allergen labels listed on your product.

What is the safety substantial? So basically these are the tests and studies that have been done to make sure that your product is safe. Usually, if you're getting your product manufactured with an existing formula with the manufacturer, they already have these sheets ready for you. It's important to have that FDA registered facility because you can actually just pull those records from them and they'll have that information. Let's say there's some problem with your brand. You can go in and have an expert come in and they can pull the research studies. And so it's not as large of a problem if you're using existing formulas with your manufacturers.

It’s also important to make sure that you understand when your manufacturer actually stops being FDA compliant. There was a recent case of us manufacturers that actually did not end up being compliant. And so it's not really a case of you using international versus US manufacturers. It's really a case of you making sure that the manufacturer that you're going with is FDA registered.

The other thing that I would like to point out is that we've been in conversations with Amazon and Walmart's Ecomm marketplace to understand what they're going to do in terms of this legislation. So Amazon has already sort of started a rough implementation of what they're gonna require. They're gonna ask you now if you were to launch to make sure that you have the FDA registration and they're going to ask for a few more information fields. They've honestly taken a larger action of kicking out third party sellers that aren't able to provide this information which is great for you as a brand because there won't be as many counterfeit goods sold for you. They haven't released official guidelines, and Walmart is still sort of working through how exactly are they going to interpret this legislation.

There is also a small business exemption. Let's say you have less than a million dollars in total revenue. You are currently exempt from MOCRA. However, that doesn't mean that your manufacturer is exempt from MOCRA – unless you're at home making your product, that's essentially fine as long as it's under a million dollars. The exceptions are if you have any eye products, such as mascara or any lip products. So even something as simple as lip gloss or lipstick, even if you're making it at home, you do have to make sure that you're registered with the FDA. And one flag here is even if you're just starting out and doing a face oil or a moisturizer, it’s important to consider that your manufacturer is certified because they legally have to be. But also because as you grow and scale, you will want to be set up with a manufacturer that is set up to scale with you as opposed to going through the process of creating a product and then needing to pivot down the line.

Next, combination products. This gets a little bit more confusing in terms of how you're marketing your product. If you have a product such as a sunscreen, which we had talked about earlier, the sunscreen actually gets registered differently under the FDA which was already a prior requirement. However, if you're marketing it as a beauty product and as a sunscreen, you actually need dual registration. You would have to actually register separately under MOCRA as well. Some of the products that I like to bring up as examples, again, it's like a blush with SPF in it. Right now according to the guidelines, dual registration is required, especially if the main focus is on this being a sun protectant blush. The rules around this are still a little bit hazy, but as we go through, it's probably better to be safer than sorry when it comes to certain products.

So what do we do? Basically, we help you with all your compliance needs: we actually help you list your product on the FDA portal, we help you manage your adverse reporting system, we can review and audit your product label and your artwork for compliance, and we can also take a look at your ingredients and provide you sort of the latest of what legislations are going to come out. So let's say, for example, you're developing a product today, but California in 2025 passes a ban they’re planning. So if they are doing that, then that means that really you want to make sure from day one that you're compliant so that you don't have to go through reformulation.

The other thing I like to point out is that if you plan on making your brand global, the EU and Canada are a little bit stricter when it comes to ingredients. And then Korea and Japan, we'll see other strict guidelines. So for everyone here, Glow comply is set up with Pietra. We've set them up like a freelancer account. So if you are in the process of developing a brand or you have an existing brand and you want to take advantage of their services, you can access them via Pietra and send them a message to get the conversation going.

Glow Comply Q&A

Question: Do you assist in global compliance requirements?

Answer: Yes, we do. We do have to take a look at your existing product to see if we actually have the availability right now to take you on for global compliance. As I mentioned, EU regulations are a little bit stricter. So if you were not within our pipeline, there are certain companies that we will not be able to do currently and we'll send them over to another partner.


Question: Someone has asked about the pricing of the compliance processes.

Answer: Yeah, so it really just depends. We do have a per product registration for smaller brands if you were a larger brand. So if you have over five products, we actually do have a custom packaging pricing that we can offer you. But if you were under five products, I can give you the rough price of registration with the FDA which is between $50 to $100 to register your product. And then all the additional services will have X, Y, Z costs associated depending on, for example, if we need your label to actually go through the legal team, that will be a little bit more expensive than if we just could like review it and just have you put down what we need you to have on the label. The second is that we can also help you with side effects for the label. So we can actually provide you a QR code which you can actually take to your preferred label maker. So we do not print labels, but let's say Pietra has some amazing label providers on their platform. We can actually give you the QR code, which you can then have your label provider put on your package and then that will have your side effect and safety reporting. This is something that I think most people like to do, especially if you have a nice eyeliner, you probably don't wanna, you know, skip all the information right then and there, but if you have a QR code, then it's very easy and simple.


Question: So curious about the cost of compliance processes.

Answer: So the local process for the US since we are working specifically mainly with us product registrations for smaller brands, the US process will be cheaper. The EU actually does have additional costs associated not just from our side, but maybe also through their regulatory agencies if you need extra things done on your product.


Question: When selling your skincare product for a Fulfillment center in the UK, but the product was made in the US, what needs to be in order?

Answer: Ok. Again, there's a lot of requirements that you need for the EU that are different from the US. We do have a checklist that we can provide you with, which will have all the details of what specifically you need to get ready for EU compliance.


Question: How would I go about registering multiple products?

Answer: Ok. So basically, you have to go through the FDA, you basically become a registered responsible person. So if you were doing it yourself, you yourself would have to serve as the certifying organization and then go through all the steps that are detailed within the FDA website. Amazing.