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.
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.