Assuming "we're already selling in the US, so the Middle East will go similarly" can throw off your first step. The US's MoCRA and the GCC's cosmetics regulations start from fundamentally different places.
The US's MoCRA (Modernization of Cosmetics Regulation Act) requires manufacturing facilities and products to register/be listed with the FDA, but this functions more as a post-market-entry notification. The GCC, based on GSO 1943, is a pre-approval structure requiring registration or certification from each country's regulator before a product can be sold. The fact that a product is selling in the US does not translate into GCC market entry approval.
The GCC's list of prohibited/restricted ingredients largely follows the EU's Regulation (EC) No. 1223/2009, while the US uses 21 CFR as its benchmark, with relatively fewer prohibited ingredients and some ingredients — like retinol — conditionally permitted. An ingredient confirmed safe by US standards may still require separate verification for the GCC.
The US tends to scrutinize the validity of claims after the fact, while the GCC, through GSO 2528, reviews claim wording starting at the registration/screening stage. The same phrase that passes in US marketing materials can be rejected in GCC registration documents.
Brands with US market experience often approach the GCC with the confidence of an "already proven product," but the two markets have fundamentally different regulatory philosophies. It's safer to treat US certification materials as reference data while preparing GCC entry as a separate process from the start.
Shukran Korea helps K-beauty brands figure out how their experience in existing markets like the US and Europe connects to GCC market entry.
If you're curious about your brand's GCC entry strategy, get in touch with Shukran Korea.
