Mapping the processes

The tidal impact of outsourcing in the production chain of 
cosmetics and personal care products led to a growing constellation of B2B operators, with an increasing number of players dealing in manufacturing, raw materials, industrial machinery, packaging…This complexification of the supply chain radically changed the role 
of contract manufacturing companies, which are now entrusted by brands to act as guarantors of the whole upstream flow. 

Documentation

The Regulation (EC) No 1223/2009 introduced a key change in terms of traceability: for each cosmetic product placed on the EU market, it is mandatory to designate a Responsible Person (RP) that must ensure its compliance with the relevant obligations and thus its safety for the end consumer. To attest this, the RP is required to compile a dossier called Product Information File (PIF), a collection of documents containing the entire ‘history’ of the product.

Even though from a legal standpoint it is the brand or importer that has an obligation to provide proof of product compliance, since the main source of information on transactions and data concerning each individual item that is put on the market is the turnkey supplier, the drafting of the PIF falls in practice for the most part within its scope of work.

As key touchpoints in the supply chain, subcontractors must in fact ensure the transparency and traceability of both materials and processes throughout the manufacturing journey of goods, from raw material and packaging procurement to bulk production, filling, and assembly, as well as any other activity linked to the making of a cosmetic product such as logistic operations.

Technical assistance

To manage this complexity, IT plays an increasingly central role – just think of revolutionary tools such as distributed ledger technologies or block chain systems. Mapping all touchpoints and processes that are involved in the development and manufacturing of a cosmetic product is the ultimate goal: by fostering a concerted approach, the enhanced inter-dependence across all players that make up the chain can not only improve traceability, but also become a driver for network integration, enabling a seamless interoperability among actors.

From a regulatory standpoint, greater access to information would speed up both the collection and production of authentic, up-to-date documentation as well as streamline authorisation procedures, at the same time allowing for a meaning-ful post-authorisation dossier maintenance. 

Automation

Beyond what we can achieve at a sector level, though, traceability is an objective that individual companies must also pursue internally. The digitalisation and automation of the industrial process are definitely key areas of improvement. Here are some application examples. 

First, there is the implementation of IT systems like Enterprise-Resource-Plannings (ERP) for an integrated management of business activities, to keep record of each step of the manufacturing process while also facilitating internal coordination and real-time monitoring.

Second, there is in-machine data collection: thanks to new generation industrial machinery and software solutions, all data related to each operation are tracked and automatically elaborated into strategic manufacturing intelligence.

One last example is robotics. For instance, one can use robotic lines for the assembly of powders that are able to recognise the decorations on the surface and insert the pieces into their trousse in a correct position. This allows for an automated quality control, which is naturally an integral part of product traceability.

Conclusion

As a matter of fact, the benefits derived from the implementation of these innovative solutions go well beyond track and trace. They enhance quality assurance and industry surveillance, resulting in improved product and workplace safety and more efficient corpo-rate governance, decision making and risk management. Finally, on a broader perspective, these technologies produce value across the entire supply network and boost research and innovation even further, not to mention their power to promote more sustainable sourcing practices. Plus, correctly digested, the verified data they generate would trickle down to the end user and encourage conscious consumer behaviour, driving ever more informed purchase decisions. A virtuous circle that interconnects upstream manufacturers to shoppers as well as all other stakeholders like never before.