You make lovely soap, everyone says you should sell it. Can you? What do you need to do in order to legally sell your soap (or other skincare) within Ireland and Europe? How can you ensure that you are proteting yourself should someone have an allergic reaction to oneof your products?
On my travels to sell and look around different craft fairs and markets, I meet quite a number of soap and cosmetic sellers. Sadly a large number are not following the legally required E.U regulations. For those trying jolly hard to comply this is so so frustrating. Many times the big giveaway is that the product is not labelled properly (Seaweed based lotion with essential oils was one of my worst 'just breathe and walk away moments' from this year AND last year- as this 'local' established business knows but is STILL not product safety assessed - fellow cosmetic makers will understand exactly what is wrong with that 'label'!!) Sometimes they are not labelled at all (every single product should be fully labelled) or it may also be extremely underpriced (read on and you'll see some of the perhaps hidden costs).
If you are selling a bought in base you still need to label it properly and if you add anything to the base - even a few drops of essential oil - these regulations still apply to you!!
So what are the steps involved in selling your soap or skincare product within the E.U?
E.U. Cosmetic Regulation 1223/2009 has been enforced since July 2013. I will try and break down the realities of that regulation
- You must be competent withyour product, making for at least a year, so that you have noticed and resolved any issues with your recipes and have been keeping good batch records.
- Your records will need to prove complete traceability of your product. So a record of each batch must be kept, given a batch no, ingredients used listed and their supplier batch codes.
- Each product will need a P.I.F. (Product Information File). Each soap/skincare is a different product and will need a seperate P.I.F. In that P.I.F will be all your G.M.P information, your steps on making the product and also the M.S.D.S for each ingredient used. (you can download these from your supplier)
- Here is a link to Just a Soap's technical blog, I found it fairly well written on these topics, informative, easy to understand and a good starting point
- Once you have decided on your recipe it will need a Cosmetic Safety Report. Personally I use Cosmetic Safety Assesments based in the Uk. They are widely regarded by many to be the best and they are reasonable. Their report is vaild in Ireland and throughout Europe. The last product I submitted for assessment was £215 for one base recipe with 6 varient ingredients. So you see it adds a lot financially to the cost of selling your product. C.S.A have clear guidelines on their website on how to format your product information. (This is only for anhydrous products- NOT using water. If you use water different product testing is required).
- Make sure you are 100% happy with your recipe before you submit it. Once you have your safety report you CANNOT step outside of its restrictions. (Another 'red herring' is when a maker might say 'Available in the essential oil or fragrance oil of your choice" This is simply not possible).
- Once you have your product safety assessment, ensure your product is labelled properly. This must use the I.N.C.I terms (so that anyone throughout Europe knows exactly what the full ingredients are), you must include your (the manufacturer) address,weight, batch number and date of product expiry. Also all of the allergens must be declared on the label (there are currently 26 that must be declared - this number may soon be increasing!)
- The product must then be uploaded onto the E.U Cosmetics Portal. (This link also has access to the user guides) Previously known as 'The Portal of Doom' it seems to be easier to use now, or maybe I'm getting a little better at navigataing it. C.S.A have a good guide on their website advising how to register and use it. Your product must be uploaded onto this central database, a photograph of the product and also a copy of the label.
- You must hold both public and product liability to sell cosmetics.
- You need to use trade approved (and certified) scales for weighing your product for the label ready for sale.
- H.P.R.A are now the governing body for cosmetics in Ireland and they are currently holding open evenings for cosmetic makers to ask questions. You can't go far wrong by asking them for advice if you need it. You need to register with your local section of The H.S.E who can also come and just take random products away for testing. Here is link to an incredibly useful facebook group for help and advice on the regulations and using the portal.
I actually dread to think how many hours I have put into all this unseen admin since I started making and especially since the legislation of July 2013. Precious hours in the evening, once my small children have gone to sleep. So to the lady who asked me at a fair earlier this year, (after asking for advice on how to use Aloe Vera in a product) "How dare you charge €4.50 for your soap when my neighbour only charges €2.50?" , I hope this in part answers your question!
To all the soapers and cosmetic makers out there who are legal and doing their best to comply, I respect you and wish you all the success in the world!!
Love Lucy xx
**This little guide is not intended as a complete step by step instruction, it is simply an overview to give new soapers and people who buy handmade cosmetics an idea of the work, cost and standard that should be going into their cosmetic products**