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I’m sure that by now most of you are aware of the pending discussion of the FDA Globalization act of 2008, that would involve (at the very least) hefty annual registration fees for small cosmetic manufacturers.
Kim from Serpentine Hair, and Lela from Bella Luccè have both addressed the ramifications of this legislation very eloquently. I am (per my usual MO) much delayed in covering, discussing, and catching up with this action. I was insanely busy last week. We worked with 4 different new retailers who will be opening shops in the fall and stocking Villainess - I say “worked with” but that involved a staggering amount of product, strategic packing, sales repping, and shipping coordination. We made tons of product, and sketched out plans for Sept-Dec’s release schedule. We shipped orders in two different installments to ensure our TAT continued in its virtual nonexistence. And we began talks with PR Agents in re: to really enabling the masses via nationwide exposure. None of that even begins to take into consideration the time I scheduled in to visit the veterinarian, the acupuncturist or the lunch w/ girlfriend I didn’t get to do.
Which, is sort of my point. We are a small company. We don’t actually have a PR budget - in fact, most of my headaches are the result of pulling off Really Big projects with Very Little funding. That takes some serious finaggling. We’re working to enrich our local economy and provide jobs in a small, rural southern town. We’re working with start-ups, family businesses in other communities - people who are willing to take the financial risks surrounding small business in the midst of an economic recession.
I admit, I have a great deal of contempt for red tape, for registration and for governmental supervision. I roll my eyes at the idea of forms, of paperwork, and the small, tedious acts of compliance that registration would require. Even so, I can see a potential need for a rulebook to ensure the consumer safety. I would argue that the existing FDA Good Manufacturing Practices and voluntary compliance are a sufficient measure.
But the proposed registration fees are considerable - we’re talking several thousand - with no consideration of a company’s gross sales or production volume. This would be… cost prohibitive. Startups will be impacted the most - imagine scraping up capital (on a single parent budget, or in addition to your fulltime job) to cover not only supplies, but thousands of dollars worth of registration fees. Existing companies will feel this expenditure as well. Small business growth is inherently frustrating - until your profit margin exceeds your goals (considerably) you will continue to work on a shoe-string budget because every cent of your profit goes towards funding new projects. I cannot imagine the impact a couple thousand dollars would have on a product development budget.
So today, Anne-Marie Faiola, Jamila White, Kayla Fioravanti, Lela Barker and Donna Maria Coles Johnson (brilliant women whose organisations I admire) are lobbying in DC against this act. I know you guys care, so please Do the reading, and sign the petition. Considering the glacial speed of proposed legislation, I can’t imagine that it’s ever “too late” to voice your objections.
Vil·lain·ess \ 'vi-lən-nəs \ n : a woman who is a villainVil·lain·ess \ 'vi-lən-nəs \ n
1 : an uncanny, articulate woman
2 : a deliberate antagonist or tease
3 : an intelligent woman in a tabloid or gossip
4 : the fall-girl in a particularly difficult situationVillainess. Redefining "bad."
Syndication:
Thanks for helping to make people aware of this; I have high hopes for a small business exemption based on what the “Drugs” portion of the act has in it (now) for small business. =)
Posted by Anne-Marie | August 12, 2008 1:26 AM