Cosmetic Safety Assessments
All Cosmetic products sold or even made and given away as samples legally require full and current Compliance.
When we finish developing your new product(s) in house our Compliance Team take over and work on the virtual PIF (Product Information File) they put this in front of our Toxicologist who works on the CPSR (Cosmetic Product Safety Report)
This is also a service available to Brands for whom we do not manufacture
We can set you up on the UK or EU portals and ensure your product is legally ready for sale
What is it?
Cosmetic compliance is a legal obligation for ensuring that cosmetic regulation is followed according to the territory in which you will be marketing your product:
UK Cosmetic regulation (EC) No 1223/2009 (UKCR) for cosmetics marketed in Great Britain (England, Wales and Scotland)
EU Cosmetic Products Regulation (EC) No. 1223/200 (CPR) for cosmetics marketed in Northern Ireland
Regulation (EC) No 1223/2009 for cosmetics marketed in the EU
The regulation states that there must be a Responsible Person assigned to every cosmetic product intended for marketing in the UK, EU including NI.
This includes every area of marketing and selling and / or giving away for free (i.e. as samples or prizes) from a small stand at a local fair, a marketplace, online and from a retail outlet/shop.
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Cosmetic Testing
Products all need to be safe to use and since in many cases the public might stick fingers into the product with the resulting ingress of bacteria or yeasts and moulds….so this means that the product will need to be preserved in some way.
To test this we will undertake a Microbiological Challenge Test…in short it’s a controlled experiment in a specialist lab where they throw bugs at it and check results over time …
In doing this they are checking if the preservative system chosen by your formulator is robust enough to ensure nothing that could be dangerous is allowed to grow
Cosmetic Stability and Compatibility Testing
These two tests and somewhat self explanatory …but there are timings involved
Stability is putting the product on test at 3 or more temperatures over a period of 90 days so it’s basically chilled, heated up and left at room temperature.
It should also be done in the container of choice ….this ensures that the product is neither too thick nor too thin to come out, doesn’t leak or fade or react in any way with the packaging material.
The product needs to hold together and not fall apart or degrade and its consistency needs to remain where it is to start with during this period
These tests are undertaken in house at our labs and should give the Toxicologist insight into their safety over the shelf life of the product (generally but not always 3 years)
If the products are already on sale in another country and have been for some time without issue this may count towards proof of Stability
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EU Labelling and Packaging Compliance
There are defined clear instructions over what should or should not be on the labelling
The print size of the product weight and where it should be on the product, the wording used, again and where, the marketing claims made are all checked before passing
We have a check list available that we can share so that you may see what needs to be on the Primary and what on the Secondary Packaging
We will also need certification from the supplier of the container as to the material used and its conformity with standards
We need to see copy that you either wish to use or have used if the product is in existence to ensure again that it fulfils the current criteria
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I have mentioned so far all the data that we need for you to gain your EU compliance through us
So in short that is:-
The full formula
All the SDS’s (Safety data sheets) and C of A’s/specification for each material used
The Challenge Test results (if needed)
The Stability Test Results and the Compatibility Results
The copy on all pieces of packaging and any certification for it
All of this we gather together in a virtual on line PIF (Product Information File) which then goes in front of our Toxicologist to produce the CPSR (Cosmetic Product Safety Report)
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The Cosmetic Product Notification Portal is the virtual place within the EU where technical data about all the products either sold or given away is stored
Each Brand must be registered and provide contact information for the person responsible for the brand. (Responsible Person or RP). Data relating to the formulation of the product is stored in the one place. This can be the full formulation with percentages, a stock formulation or preferably it can be a banded formulation showing all ingredients within a range of 10%. E.g. ‘from’ and ‘to’ so between 1% and 10% for example).
A CPSR (Cosmtic Product Safety Report which includes test results such as full Microbiological Tests, Compatibility with Packaging, Stability over time and the full toxicological review must be available on demand. Data such as the copy used, the specification on the packaging must also be held
It is essential that everything is included as this site needs to be accessed by the poisons agencies of the EU so that they can evaluate what may or may not be a problem if someone has misused the product and/or had an allergic reaction Allingham Beck Associates Ltd. provide a service collating and uploading all this data, setting your company up on the portal and monitoring changes
We can offer the total management solution for this legal requirement.
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Allingham Beck Associates undertake International Compliance for Brands within the UK/ EU but we also look after some brands from outside the EU wishing to sell in the EU marketplace
Some are Brands which are manufactured in China or the USA for example which are brought into the EU/UK by residents to sell
The degree of Compliance already undertaken on these is hugely relevant and since this also involves the Brand/Manufacturer releasing the full formulation (OR AT LEAST A BANDED FORMULATION WITHIN 10%) amongst other things this can be quite a challenge
We ask that the importer undertake the liaison with their principle and provide us with the necessary documentation for us to complete the paperwork required
We can support them through this operation providing them with a checklist that they can tick off as received
We monitor the FDA and other bodies for changes to legislation or warnings as to materials that may be no longer allowed or are being questioned as to future inclusion
We monitor changes in acceptable levels of fragrance materials recommended by IFRA (INTERNATIONAL FRAGRANCE ASSOCIATION) whose recommendations are generally accepted as a compliance must.
We also are aware of, and have a working knowledge of a number of countries requirements outside of the EU and can assist with many, although not all of these countries.
Clients are advised to check with us where they wish to sell to or buy from before assuming they are covered or that we will know what’s required
EU Compliance is probably the most widely accepted set of standards in the world with many countries outside the EU adopting it as their own and expecting imported brands to reach this standard. However having EU Compliance does not mean your products are suited to sell everywhere for example labelling requirements vary from country to country.
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The regulation states that there must be a Responsible Person assigned to every cosmetic product intended for marketing in the UK, EU including NI.
This includes every area of marketing and selling and / or giving away for free (i.e. as samples or prizes) from a small stand at a local fair, a marketplace, online and from a retail outlet/shop.
Our sister company TRP offer full responsible person services
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Cosmetic Compliance FAQs
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UK & EU Cosmetic Compliance Simplified
We’ve been there since the start
Cosmetic compliance came into law in 2013 and we were there from day 1.
As a business we constantly monitor changes in legislation and flag any likely issues to the Brand
We have an experienced team to guide and support you through the complex work of cosmetic compliance.
Don’t just take our word for it!
Client Testimonials:
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Precious Brands, Kingston Upon Thames
When it comes to compliance you need to have absolute confidence in the people and the company not only to carry out what is legally required but to be a trusted partner, enriching your understanding and most importantly being your 24/7 guardians. We are eminently confident to have found that in the team at Allingham Beck and sleep easier in the knowledge that they care about our business.
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Michael Williamson CEO/Founder – ThickTails by KMX Healthcare Limited
I have used Allingham Beck’s compliance services on multiple occasions for a range of products and continually find them engaging, professional, well informed and willing to actively work with the client on a partnership basis. I would highly recommend them.
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Nugg www.nuggbeauty.com
I highly recommend Allingham Beck Associates for their regulatory and compliance services. The team is extremely knowledgeable, highly skilled, reliable and diligent and a true pleasure to work with!
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Gretchen Berra Bobbi Brown, Montclair, New Jersey
‘When we were expanding out supplement line into the UK, we were recommended to Allingham Beck to help us navigate the EU regulatory system. They were incredibly knowledgeable, responsive, professional, and patient with us throughout the entire process. They became an integral extension of our team and were brilliant partners to us, we could not recommend them more!