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Technical Section

This section contains the MSDS sheets, Analysis sheets and more.  Plus information about our products and the cosmetic world.


CPNP - what you need to know

Monday, 2 January 2017 11:30

CPNP - the Cosmetic Products Notification Portal

If you are manufacturing and or importing your own cosmetic products it is now your responsibility to register then under the CPNP, effective from July 2013 under the European Cosmetics Regulation 1223/2009.  This is a European wide portal so you will only have to register your products once and it must be done premarket.

The aim is that all products will be centrally registered with the details of the ingredients, formulations and packaging information so that in the event of any poisoning or medical incidents involving a certain product, then the information about what it contains will be available Europe wide.  It's all about the safety of the product.

You will firstly need to register with a username and password at the CPNP portal, then register your company and then link the two.  Finally, add your products in.

The Official User Guide can be found here.

A more readable guide can be found here courtesy of Cosmetic Safety Assessments - all credit to Scott Grainger for this.

 

GMP - what's it all about?

Monday, 2 January 2017 11:22

GMP or Good Manufacturing Practices - what does it mean?

As of July 2013 and the EC Regulation 1223/2009 it is now mandatory that all cosmetics are produced with GMP (page 2 section 16).

This makes good sense for everyone as it means safe products, consistent products and so it's good business all round.

So what are the points that need to be covered?  Is it just a case of working in a clean room?  Most of the points are obvious and you probably do them anyway.  But by documenting and recording everything below you will get into the habit of GMP without even thinking about it.  We've highlighted the main topics and given you some pointers as to what you should be doing when compiling your GMP procedures and keeping your records.

Personnel

  • Who will make the products.
  • how will they recognise the ingredients.
  • have they been trained on what to do.

Premises

  • are you working in a clean area.
  • is it in a good state of repair.
  • are you able to prevent the risk of cross contamination.

Equipment

  • is the equipment easy to clean.
  • is it suitable for purpose.

Raw Materials & Packaging

  • where do you store the raw materials.
  • how do you rotate the stock.
  • how are the raw materials stored.

Production

  • how do you make the product.
  • what order are the ingredients added in - does this matter?
  • are there any temperature controls needed

Finished Products

  • what should the finished product look like.
  • does it meet the defined acceptance criteria.
  • is it consistent.

Quality Control

  • Is there a procedure in place for quality control.
  • what happens when things go wrong.
  • what happens if the incorrect ingredient is added.

Treatment of Products out of Specification

  • what do you do when something goes wrong.
  • have you changed supplier or ingredient.
  • any changes should be controlled and documented.

Waste

  • what is your process for handling the waste.
  • do you follow local guidelines.

Outsourcing and Sub Contracting

  • do you have a written agreement with the third party.
  • how are you checking the third party is working according to your requirements.
  • do you regularly audit the third party.

Deviation

  • do you have a process to cope with deviation - what happens when a product hasn't turned out quite how expected.What do you do.
  • did you use different equipment.
  • any changes must be controlled and documented.

Complaints & Recalls

  • what do you do when someone says they don't like your product.
  • what is your process for handling and investigating complaints.
  • do you need to do a recall - what process do you have in place for this.

Change Control

  • remember to document any changes you make to the manufacturing process.
  • have you changed supplier for example.

Internal Audit

  • you should have a process to continually monitor performance.  Manufacture is an ongoing process and standards need to be maintained all the time.  This means you will get a consistent product.

Documentation

  • make sure you record what you do.
  • document everything!

Josie McCaffrey

The first thing to remember with Selling Your Cosmetic Products is the reason that all the legislation exists.  The main point is consumer safety.  It is only sensible to ensure that any cosmetic product that is available for purchase is safe for use.  We have legislation to make sure toys are safe, cars are safe, electrical goods are safe, food is safe so this is just the same thing.  If you are serious about selling your products then you need to do it legally regardless of whether you are selling in a shop, market stall, online or as a distributor.

So firstly what is classed as a Cosmetic Product?

It is a substance or mixture which is applied externally to the human body (skin, hair, nails, lips and external genital organs) or to the teeth and mucous membranes of the oral cavity and provides a cosmetic function.
So from our point of view, soaps, bath bombs, lip balms, body lotions would be classed as a Cosmetic product.

What are the rules for selling cosmetic products?

From 11 July 2013 there is now one legislation across the whole of the EU. Before this each country had their own variation but now there is only the one – it is the EU Cosmetics Regulation No 1223/2009. This is good news as it means that your safety assessment, central notification and labelling will be applicable throughout the EU.

Who is responsible for following the legislation?

This would be the brand owner or company distributing the cosmetics. If you import goods from outside the EU, then it is your responsibility to comply with the legislation. If you manufacture the goods then it is your responsibility.

Who checks that you are doing it right?

The Trading Standards Officers are able to enforce the regulations.  Each local council will have a Trading Standards department.

So what do I have to do?

Before you can offer your cosmetic products to the market you will need to start and maintain the following:

The PIF. This is the Product Information File and needs to be compiled before selling your goods. It must be in the national language and it needs to be kept for 10 years after the last batch has been produced.  It is a record of how your product is made, what ingredients are used, where did they come from etc.  CLICK HERE for further information.

Safety Assessment – each recipe will need to undergo a safety assessment to ensure the product is safe for the general public and then a Cosmetic Product Safety Report (CPSR) is produced . A suitably qualified person will look at the formulation, ingredients and confirm that the product is safe to use.  You will need provide as much information as you can about your product/formulation/ingredients to the Assessor in order for them to complete the Safety Report.  This includes the product description, product formula, perfume allergens (found on the MSDS information), manufacturing procedure (how do you make your product), labelling information, claim substantiation (if you are making claims about your product - how are you substantiating these claims).  The more information you provide, the quicker the process should be.

CPNP – the Cosmetic Products Notification Portal. This is an online system where you “register” each of your products and it confirms the safety of your product. It applies to the whole of the EU and must be done pre market. The whole point of this system is safety and so it records lots of information about your product – name, its purpose, a photo, the company details, formulation.

Labelling – your products must be labelled correctly. The information must include the name of your product, its function, the EU address of where the PIF is held, the country or origin if the product is made outside of the EU, weight (unless it is a free sample of weighs less than 5g or 5ml or a single application item), the batch number, the best before date or period after opening date, and the Ingredients.

Ingredients must be made with the INCI names and in descending order. Colours are referred to as their CI (colour index) number and are usually put at the end of the label.

Fragrances are referred to as Parfum and Flavours are referred to as Aroma.

By using this method, the labels can easily be read and understood in any language.

Claims – you must not make any misleading claims and any claims made must be fair, true and have evidence to back them up. You may see products with claims such as “no nasties in our soap” - this claim is unfair and misleading and implies that other soaps are made with “nasty” ingredients. So unless you can prove your claims with scientific evidence it is best not to make them.

GMP – good manufacturing practice

GMP is now a mandatory requirement for the production of all cosmetics as of July 2013.

It includes 15 different aspects of GMP and covers maintaining equipment, hygiene, defining procedures, regular checking, maintaining records and more. We have put together a separate information file on GMP going into more detail about what is involved.  CLICK HERE to access.

Conclusion

While the regulations can sound scary and daunting, they can be followed easily.   We aim to provide as much information as we can on the website to help you with the process.  We aim to source from the same suppliers so we can ensure that we have continuity of the quality of our raw materials so you can create the best products. Building close relationships with our suppliers means that they know and appreciate the high standards we require.  After 10 years in business we know that good quality is achievable and is what our customers expect.

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