In short
A market requirements matrix puts your target markets side by side, duty by duty, with every cell sourced and dated. It shows what's shared, what's different, and what a new market would actually add. The market overview and your Level 10 checklist took one market at a time. This is for planning across them. It isn't legal advice, and anything you rely on should be confirmed by a professional in that market.
What you will learn
- Build a dated matrix across at least three markets
- Trace each cell to a primary source
- Identify shared and market-specific work
Before this lesson: GMP Thinking for Small Makers
A starting matrix
| Duty | EU | Great Britain | US (MoCRA) | Canada |
|---|---|---|---|---|
| Who is responsible | Responsible Person in the EU | Responsible Person with a UK address | Responsible person, as defined by MoCRA | Manufacturer or importer: check the rules |
| Before sale | CPNP notification | OPSS notification | Facility registration, product listing | Notification; a 10-day rule is noted in our log |
| Safety evidence | Safety report by a qualified assessor | Safety report by a qualified assessor | Adequate safety substantiation | Check requirements |
| File | Product information file, 10 years | Product information file, English, 10 years | Records of substantiation, etc. | Check requirements |
| Allergens | 0.001% and 0.01%; expanded list under 2023/1545 | Check the current GB position | FDA rule awaited at our last check | 0.001% and 0.01%; SOR/2024-63 |
| Adverse events | Serious effects reported | Check the guidance | Serious events within 15 business days | Check requirements |
| GMP | Required; ISO 22716 presumption | Required; ISO 22716 | FDA rule awaited at our last check | Check requirements |
"Check requirements" means that we haven't confirmed this for this table, and that's what you should write too rather than guessing. Northern Ireland, and each country's labeling language rules, need their own entries.
More rows to add
- Label language, and required statements.
- Ingredient naming.
- Claims rules.
- Shipping and hazard class. See shipping perfume and flash point.
- Tax on alcohol or fragrance, and customs codes. See HS codes.
- VOC limits, such as those in California. See the VOC guide.
- Local disclosure rules, such as California's.
- Wildlife or plant trade rules for your materials.
Reading it
| Type | Meaning | Example |
|---|---|---|
| Shared core | One piece of work serves several markets | Formula record, composition data |
| Adapted | Similar, needs changes | Safety report, label |
| Separate | Each market needs its own | Responsible party, notification |
| Constraining | Shapes the formula itself | A prohibited material in one market |
That last one is very important. A formula built for the most restrictive of your intended markets may avoid a later reformulation. Yet it may also cost you character in places where you don't need to give it up. That's a decision to make with evidence.
Keeping it current
- Date every cell, and name the source.
- List the triggers for review: an IFRA notification, an FDA final rule, a GB decision on allergens or a new date under CLP.
- Set a recurring check, and subscribe to official updates where you can.
- Where a commercial summary or this Academy disagrees with an official source, the official source wins.
Estimating work
For each new market, list actions, who does them and rough elapsed time, and find out actual costs. We give no prices, since they vary and date quickly. Compare markets by the work and by the risk they add. A small maker may do better to do one market properly than three poorly.
Practical exercise: A three-market matrix
- Choose three markets you could really sell in, or that interest you.
- Build a matrix with at least ten rows, starting from the table above and verifying each entry at a primary source.
- Date and source each cell. Write "not confirmed" wherever you couldn't.
- Classify each row as shared, adapted, separate or constraining.
- Check your own formula against the constraining rows.
- Write a half-page recommendation on which market to do first, and list what you'd ask a professional.
You have done this well if each cell has a source and date, gaps are visible, and your recommendation is based on your classification.
Common mistakes
- Copying a summary as fact. Go to the source.
- Treating the EU as a template for everywhere. Many duties differ.
- Leaving out dates. Undated cells become false quietly.
Knowledge check
Written and reviewed by the RUŌOD Lab team. This is general education, not legal, regulatory, medical or safety advice. Example dilutions and exercises are for learning, are not validated products, and have not been safety-assessed. Completing a lesson confers no qualification. How we check these lessons.