Interview with Geoff Waby – Expert in the US Modernization of Cosmetics Regulation Act (MoCRA)

June 14, 2024. We are glad to announce our new series of interviews with experts from the cosmetic industry. Our aim is to inform our readers about different professions within the industry and get to know their views on different topics.


We had the pleasure to interview Geoff Waby – he is one of COSlaw Editorial Committee members and Board Director of Obelis USA.

Geoff Waby has more than 35 years of experience in Quality Assurance and Regulatory Affairs covering OTC drugs and cosmetics. He was the quality assurance lead for Procter & Gamble in Europe, the Middle East and Africa, before holding the same role for Estée Lauder, firstly in Europe, followed by North America. He served on committees with Cosmetics Europe and is an active member of the Personal Care Products Council. He is co-chair of the PCPC Manufacturing Hygiene task force and an adjunct instructor in the James L Winkle College of Pharmacy, University of Cincinnati. Geoff is an expert in the Modernization of Cosmetics Regulations Act, 2022.

Can you briefly describe your job?

I am fortunate to have a number of roles. I am a Board Director of Obelis USA. I am an independent consultant and an adjunct instructor at the University of Cincinnati. In the past I have been responsible for Quality Assurance & Regulatory Affairs in Procter & Gamble, Estée Lauder and Bureau Veritas.

Can you share with us what made you decide to start your career in quality assurance for cosmetic products and over the counter drugs (OTC)?

I began my career with P&G in the supply chain. I had a wide variety of roles at the beginning, and when P&G decided to establish a Quality Assurance department I joined as one of the first members. I enjoyed the role because in addition to the supply chain, the Quality organization covered product and packaging research and development as well. Because of this, I have been able to work with all parts of the company, in Estée Lauder this increased to include the commercial organizations and business leadership. I like to have this breadth in my work.

How does your job influence you when purchasing cosmetics?

It has made me very conscious of the quality of the product and package, and the selection of ingredients. For example, I am more aware of sun damage to the skin than I would have been otherwise.

You worked for big companies such as Procter & Gamble and Estée Lauder – what is the most important thing you have learned from this experience?

I was very fortunate to work for companies which understood that the best way to have a successful business was always to do the right thing for anyone buying and using your product. This meant that there was a strong emphasis on getting things right the first time – selling a safe and effective product which lived up to the promise it made to the consumer and enhanced the equity of the brand name.  It also meant when things went wrong and a product ended up on the market which did not live up to the promise, the best thing for the business was to be open about that, get it back from the market and replace it with product which did deliver the intended benefits with none of the potential risks. This created in me a firm belief that you need to be honest, transparent and align your actions to the best of intentions for clients, consumers, partner companies and everyone involved. A successful business, with respect for everyone involved, makes a growing business with benefits for everyone.  This aligns with my own personal values and beliefs.

You are an expert on the US regulatory framework for cosmetics and OTC – what is your advice to a company that would like to enter several markets with their products?

Firstly, I would say that cosmetics is a great market to be in. It is directly related to health, well-being and self-expression. Globally, it covers a diverse range people including minorities and disadvantaged groups of people. For anyone who is oppressed, undervalued or otherwise feeling down, cosmetics can be a means to give themselves some self-care. The same applies to the population in general. Although cosmetics are sometimes thought to be frivolous compared to food, drugs, medical devices etc., and they certainly don’t offer the direct life extending benefits of drugs for example, they certainly offer life enhancing benefits to many people. I would say to a company that they need to keep up to date with regulations around the world and formulate their products to meet all of the major regulatory requirements. This is the best way to keep their product portfolio simple and avoid different product variants for different markets. Cosmetics regulations are changing rapidly – ingredients from the past are no longer being used, sustainability and essential ingredients only are powerful movements, driven by major global forces, cosmetics are using more naturally derived ingredients. These changes will continue and put more demands on companies who want to participate in this large and attractive market.

At COSlaw, we handle regulatory compliance. Many times, companies see regulatory compliance as a burden that limits innovation. What do you think about it?

I have always found that the regulators, such as the Food and Drug Administration, take the oath they swear to uphold the public health of the US population very seriously. As I have already pointed out, I have been fortunate to work for companies who, for business reasons, were equally committed to that goal. Of course, when the FDA is in your plant or across the table from you, they ask important questions and you have to justify the decisions you took and the things you did. If you can fall back on an honest desire to do the right thing, be driven by good science and be transparent and accountable for your actions, then you can face those questions with confidence and work jointly for a good outcome. So there are costs to staying compliant and there are limits on what you can do, but costs and limits can also drive innovation, and if you are constantly searching for an attractive product which is safe and effective and contributes to the deep relationship which consumers develop with their cosmetic brands, then it is easier to understand when you have to innovate to meet these goals without an ingredient which you used to use. It is much more difficult to understand when you lose an ingredient because it becomes labeled in the minds of consumers as a problem, when there is no scientific evidence to support that conclusion. This does happen, and the industry has to continue to find ways to educate and to promote good science.

In your opinion, what are the challenges that the cosmetic industry is currently facing and how can they be overcome?

Microbiological contaminations cause more recalls of cosmetic products from the US market than all other reasons combined. This is made worse by more naturally derived formulations and ingredients, which can carry a higher bioburden than heavily processed ingredients and a loss of robust preservative systems which used to be available to use. All manufacturers must review their facilities, equipment, operating practices, training and education, which were developed when formulations were more resistant to contamination, to match the market driven changes. The Personal Care Products Council in the US created a Task Force to address this, and we were able to introduce a new course in Hygienic Manufacturing to the 50-year-old Cosmetics Science program of the University of Cincinnati. The course has been extremely well received, with a large number of students signing up to be trained in the challenge of addressing the risk of microbiological contamination of cosmetic products.


Did you like this article? Contact us to let us know what other professions you would like to know more about.

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