What’s A Small Business To Do?
This presents an obvious challenge for small businesses. They either have to join PCPC (PDF) at a minimum annual price of $640, and then purchase the INCI information for a minimum of $495, or they have to purchase the information without joining for between $795 and $995. It would be one thing if using INCI names was optional, but it’s not. Requiring companies to pay a fee to a private non-profit entity in order to access information that is necessary (not optional) in order to comply with the law amounts to a barrier to entry into the cosmetics arena. Small businesses have adapted by getting the INCI information from second-hand sources. That is, people purchase the information from PCPC and then share it with others. This behavior obviously solves the small manufacturer’s labeling problem, but only to the extent they can trust the second hand source. (Of course, the fact that the INCI dictionary bears the PCPC copyright ownership notice is another issue altogether.) The bottom line?
