Anne Dux, Director of Scientific and Regulatory Affairs, FEBEA
For an exporter of cosmetic products, the Certificate of Free Sale (CFS) is a real passport, an open sesame without which it is impossible to export to some countries. Concretely, the CFS certifies that the mentioned products can be freely marketed in their country of origin, in other words, that they comply with the country regulations. It enables requesting countries to check that the product complies with regulations sometimes more stringent than in their own, and to make sur that products were not just specifically formulated for export.
In France, it is the French trade association (FEBEA) that, since 1968, delivers the documents under the authority of the Ministry of Industry. This is not a unique case since, in the United States, the trade organizations also issue the CFS. The FEBEA claims having issued several hundred of thousands of these export documents to all cosmetic companies who had requested them, members or not of the trade association, while specifying that it had been done "under such security conditions that no company had been questioned".
The procedure for issuing a CFS has nonetheless been reinforced, since the FEBEA announced that its procedures had been certified by Intertek, as complying with quality assurance standard ISO 9001:2008.
Should one see in this initiative a will to stand out, while since April 2010 1st, COSMED, the other association representing the companies operating in the sector, also has a ministerial accreditation, putting an end to more than forty years of monopoly? At the FEBEA, we were told that the two facts were unrelated. "The certification process was initiated more than a year ago", underlines Anne Dux, Director of Scientific and Regulatory Affairs. "The implementation work lasted a short year, it involved twelve employees, representing half of the staff of FEBEA!".
It is actually the whole chain of issuing - from the packaging audit to the checking of the INCI list - which was put under scrutiny and in line with ISO requirements. For the Febea the aim is to ensure quality in the procedure of issuing and in the service provided to businesses, but also give even more credibility to its own documents in the eyes of foreign authorities. Because, as we were explained at the FEBEA, "in the case a problem occurs, the receiving country could be entitled to ask for some details on the procedure of issuing".
In the event of a problem which could be for example an accident with a non-complying product to Franco-European regulations but yet displaying its CFS. With 18,000 to 20,000 CFS issued annually, the need to consolidate the procedure of issuing seemed logical. "And this will have no impact on the cost of the document issuing," said the FEBEA.
The Certificate of Free Sale is currently required for export in some sixty countries, including heavyweights like as China, India, Russia, South Korea, and Brazil.
