Currently, the Middle East and North Africa (MENA) is believed to be a promising market for the beauty industry, with a strong demographic push and increasing purchasing power. According to the British Beauty Council, the beauty and personal care market in MENA is currently over 46 billion USD and estimated to reach 60 billion USD by 20251. To help enterprises explore this emerging market, ChemLinked interprets the cosmetic requirements in three main areas, Egypt, the UAE, and Morocco through this article.
Egypt
According to Law No. (151) of 20192, in Egypt, cosmetics are defined as any substance or preparation intended to be placed in contact with various external parts of the human body (epidermis, hair, nails, lips, and external genital organs) or with the teeth and the mucous membranes of the oral cavity, for the purposes of cleaning, perfuming, changing appearance, correcting body odors, and maintaining good condition.
Egyptian Drug Authority (EDA) is the competent authority for various medical and biological products, including cosmetics. The Central Administration for Pharmaceutical Preparations (CAPP) under EDA is responsible for the evaluation and registration to ensure the quality, efficacy, and safety of products. Only cosmetics registered with CAPP can be sold in Egypt.
To register cosmetics and place them on the Egyptian market, enterprises should submit the complete documentation of the cosmetic product via EDA’s electronic platform. After an official review, a notification number will be automatically issued to the applicant within 10 working days. If through the fast track, the notification number can be issued within 3 working days from the date of fulfilling the notification requirements and paying the prescribed fees. The notification is valid for ten years from its issuance date, and can be renewed under the applicant’s request in the last year of the validity. Please note that the notification will be considered cancelled when it expires without being renewed.
Information to be notified include :
The product’s trade name.
The company name and address are needed to facilitate communication, access information about the product, and authorize the product-owning company to notify relevant parties in the event that the applicant differs from the manufacturer.
A product composition form containing the scientific names of the substances included in the composition as well as specifying the quantities and percentage, be in w/w% (weight per weight) or w/v% (weight per volume) and the function of each substance.
The artwork of the product
A payment receipt of fees and services fees and any other dues in accordance with the law and rules of the Egyptian Drug Authority.
The shelf life of the product.
A free sale certificate from the country of origin for imported cosmetic products. The certificate shall be sealed by the competent accreditation authority and authenticated by the Egyptian embassy or consulate in the country of origin. It shall indicate that the product is freely sold in the reference country. It shall be submitted only in the case of seeking recourse of circulation reference (i.e. in the case that the parent company or manufacturer belongs to a non-reference country, but the product is freely sold in a reference country. In this case, the free sale certificate as the circulation reference shall be submitted). Circulation reference shall be determined by the headquarters of the parent company owning the product or the country in which the cosmetic product is manufactured or circulated.
Notification authorization from the product-owing company abroad to the agent in the Arab Republic of Egypt. The Authorization shall be sealed by the accreditation authority and authenticated by the Egyptian embassy or consulate in the country of origin (in the case of imported products).
The manufacturing contract for the products of toll manufacturing indicating the storage location (the factory store or the accessory storehouses of the factory), provided that it shall be licensed by the authority. The contract shall be sealed by the accreditation authority and authenticated by the Egyptian embassy or consulate if the manufacturing contract is licensed from abroad.
In the case of the claims mentioned on the outer package, a scientific reference or scientific studies shall be provided to prove the effectiveness of the substance for its intended usage purpose.
If the cosmetic contains any ingredients that have special requirements in accordance with the European directives, a clarification letter for these requirements shall be submitted. Besides, although not mandatory, a halal religious conformity certificate is recommended.
After obtaining the notification number, enterprises can ship the products to Egypt. The EDA will line-by-line inspect the products at the warehouse against product notification. The notification number and expiry date should be printed on the goods. If any deviation is found between the product and the notified information, the custom inspection will be suspended and the products will be blocked at the warehouse until the company updates the notification, or re-notifies all the information.
United Arab Emirates
United Arab Emirates (UAE), located on the Arabian Peninsula, is a federation of seven emirates, namely, Abu Dhabi, Dubai, Sharjah, Ajman, Umm Al-Quwain, Fujairah, and Ras Al Khaimah.
In UAE, the Ministry of Industry and Advanced Technology (MOIAT) is responsible for developing and implementing policies related to industry and technology, promoting innovation, as well as enhancing the country's industrial sector. MOIAT oversees various certifications to ensure product quality and safety in the UAE market.
The certification system under the MOIAT is broadly divided into two, namely Emirates Conformity Assessment Scheme (ECAS) and Emirates Quality Mark (EQM). ECAS is a mandatory certification, while EQM is voluntary. Currently, ECAS is widely applied to various consumer goods and some industrial products, including cosmetics and personal care items. Obtaining an ECAS certification is essential for marketing cosmetics in the UAE, as it indicates that the product is safe for UAE citizens and complies with international standards. Please note that the ECAS certification is valid for only one year and is subject to annual renewal.
To obtain the ECAS certification, enterprises should submit the application to a certification body approved by MOIAT. At present, 19 certification bodies are designated by MOIAT.
The ECAS certification application documents to be submitted include:
Valid UAE Industry/Trade License
Registration certificate for Industrial Measurement System
Test Report from accredited and recognized laboratory according to Gulf standard, UAE.S GSO 19433
Formula Declaration with ingredients and percentage issued by the manufacturer
For Imported Products: Free sale certificate on the manufacturer letterhead (Legalization is not mandatory; third-party certificate is accepted as well)
Representative artwork and label of the product according to Annex No. 1 of the cabinet resolution No. 18 of 2014
Product safety report according to Annex No. 3 of the cabinet resolution No. 18 of 2014
Electronic Declaration of Conformity
Apart from the submission of all the above-listed documents, compliance of the below five technical requirements is also essential:
1) Safety and Quality Requirements
No Islam-prohibited substances shall be contained in the product. The product should maintain optimal condition within its shelf life, and show no harm to consumers when being used following the product directions.
Safety testing must be conducted as specified in Gulf standard, UAE.S GSO 19433 and Annex 2 of the original document, with proof provided through test reports that comply with Annex 3.
The product's form, color, fragrance, packaging, and labeling must not be designed in a way that could confuse it with food.
2) Manufacturing Requirements
Manufacturers should conduct production in compliance withISO 90014 or GSO.ISO 227165.
3) Metrological Requirements
The product should be in compliance with the metrological requirements in UAE.S GSO OIML R876.
4) Packing Requirements
Containers used for packaging should be in compliance with UAE.S/GSO ISO 227157, and glass materials must be in compliance with UAE.S/GSO 20938.
Packaging materials should not chemically react with the product contents and can maintain optimal conditions.
5) Labeling Requirements
Labeling should be in compliance with Gulf standard, UAE.S GSO 19433, with all information provided in both English and Arabic.
The shelf life must be indicated as either the “Date of Minimum Durability” or the “Period After Opening”. Images and claims against social customs or suggesting medical effects are prohibited.
Morocco
In 2012, the Moroccan Ministry of Health released the CIRCULAR N° 48 DMP209, which requires cosmetic registration with the Direction du Médicament et de la Pharmacie (DMP). This circular sets out the general principles similar to European cosmetic regulation, such as the prohibition on the use of "substances known to be carcinogenic, mutagenic or toxic to reproduction" in cosmetic products. The circular also indicates that the Annexes of EU Directive 76/768/EEC10 directly serves as its reference.
In addition, Morocco established the Cosmetology Committee through the circular. The committee is responsible for reviewing registration applications and advising the Minister of Health on all matters related to the suspension, cancellation, or prohibition of cosmetic sales in Morocco.
To be registered, cosmetics should meet the requirements set out in the circular, especially those for safety, composition, and labelling. The manufacturer, packer, or importer of the product should also declare their activities and have a qualified staff responsible for quality control and product safety assessment.
The registration document consists of an administrative part and a technical part. In addition to the usual elements such as corporate identification, product identification, etc., the administrative part should contain a certificate of deposit from the Poison Control and Pharmacovigilance Center. The technical part includes the qualitative and quantitative composition of the product, the monogram, and the specification of the raw material, the microbiological specification, the analysis result of the finished product, the name and address of the qualified and responsible person, proof of claim, etc. The registration is valid for 5 years from the issuance date. A renewal application should be made three months before its expiry date.
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