Making Cosmetics in the UK & EU the rules.
What you need to know about making and selling cosmetics in the UK & EU
With the introduction of YouTube and content creation on social media, making bath bombs and soaps ect seem like an extremely easy way to start a business. This is not the case in the UK / EU.
In the Uk /EU you need to have products tested to the highest possible standard by a Chartered Cosmetic Chemist. A Cosmetic Product Safety Report CPSR also known as an Assessment is a professional document that the Chemist produces from your documentation and rigourous testing.
In the UK many companies, EazyColours being one of them, have taken SOME of the hard work out of creating your products by selling Multi-Assessment CPSRs. These are not an easy way in to the cosmetic industry. These are Professional Documents that you are required to TEST yourselves before putting any products on the market to sell. EazyColours has tested and created the recipes that are assessed, but it is up to the Responsible Person to re-create and test these recipes before they go on sale to the public.
Just like buying a recipe to bake a cake to start a cake shop, if you've never baked one before, you cant expect to make a viable business out of selling your first one, without practice and more PRACTICE. Multi-Assessment recipies still need practice and your own testing.
In order to sell legal cosmetics in the UK and EU you must be complying to the industry standards. In todays blog we will discuss GMP, PIFS CPSR's and Insurance in order to be a legal cosmetic business.
You need to research the laws and regulations surrounding Legally Selling in the UK & EU.
This blog is a brief outline of what you need to know. 90% of starting a business is RESEARCH.
Firstly you need to create a PIF or Product Information File for each product you create. You must include all the legal information in this file that pertains to the production of your cosmetics.
Before you make any products you must have a suitable working environment that follows GMP> GMP is the industry standard Good Manufacturing Practice and is the foundation you build your business on.
You must comply with the rules and regulations surrounding GMP as well as the laws covering creating the products such as a CPSR and insurance.
GMP covers your production area as it needs to be maintained to a high level of cleanliness. It needs to be suitable for the creation of cosmetics away from any form of contamination ie food from a kitchen.
-There needs to be adequate lighting and ventilation.
-Your tools must only be used in the production of cosmetics, properly maintained and checked for defects before every batch is created.
-All equipment, including electrical will be used correctly and all safety precautions adhered to according the manufacturers guidelines.
-All ingredients will be stored appropriately according to their needs
-All containers must be accurately labelled so that the contents are easily identifiable.
What information needs to go into my PIF?
Firstly lets start with A Good Manufacturing Practice Statement. This is a document that is required to show you know the rules and regulations about basic hygiene and that your production area is kept to a high standard. You have to have this document in your PIF for traceability and accountability should you ever need legal advice against any claims made against your products.
Your GMP Statement Document must include the following information:
-You should detail cleaning routines and pest control procedures.
-There should be no smoking, drinking or eating during the production of your products;
-A high standard of personal hygiene should be observed. Gloves and protective clothing to be worn.
-Written documentation of your entire production process and procedures when creating each batch of product needs to be in your GMP statement. This is all the details of how you make your batch after you have detailed your cleaning processes. You must include your entire process from weighing, creating, and batch numbering.
- Details of your testing that you carried out BEFORE you sell any products.
-Your retained samples of each batch must be stored and kept free from contamination for future testing and for monitoring purposes in case you need to batch recall.
-You must state that there is no deviation at all from the CPSR (your assessment as this will leave you uninsured and illegally trading)
-Your CPSR (Cosmetic Product Safety Report) is your assessment. This needs to be stored in your PIF
You need to have batch code for each batch of product you create. These are your own identifying codes given to each batch of product you make.
-Suppliers contact details. Every company you buy raw ingredients from needs to be include in your PIF
-MSDS for each ingredient you have in your batch.
-IFRA statements for Fragrance oils/Essential oils
-Allergen declarations for Fragrance /Essential oils
-Certificate of Analysis (COA)
-Declaration of non testing on animals
You will need to add to your PIF every time you create a batch of a product. You need to keep this file updated with new msds ect every time you use a new ingredient.
Product labelling is also required for your PIF as well as details of the packaging you have used. Your Labels must be compliant with UK /EU law and have all the necessary requirements including, name and address of business premises the products are made in,
INCI names in descending order, batch numbers and allergens ect.
For each product you make you will need to register them on the CPNP Cosmetic Product Notification Portal for the UK and EU member states. This portal is absolutely required to add all products that you sell.
You have to follow Regulation No# 1223/2009 (Article 13) that states you must notify the CNPN before any product is placed on the market for sale to the general public.
You will also need Public and Product Liability Insurance.
If a customer or a member of the public makes a claim against you, public and products liability insurance will cover the legal defence costs and compensation you may have to pay out. Even if it’s not your fault, you may be sued and liability insurance is very much required.