Let’s start at the top and try to demystify Cosmetic Compliance as we go along:
- To sell or sample (yes even free samples) legally in the UK/EU you need to be EU or UK Compliantor both and that requires your products be registered onto whichever or both portals…this is not a total waste of time, it’s actually a really good safety measure! The new UK Portal or the SCNP went live at the end of 2020 and all Brands will need to be on it and their cosmetic products registered by the end of March 2021 or face possible fines. Once registered on either portal it means that should anyone ingest, eat drink or be merry with your product and fall ill, the Poisons agency in whatever country they are in, can access that data on each and every raw material and ascertain from this what best to do.
- If you are the Brand Owner responsible for the product being developed you are probably going to be the Responsible Person here in the UK, this can be your company but it can also be another company (as explained we have set up a sister company to offer this service) whoever it is must be able to access the data and be able to respond if Trading Standards for example were to contact them. Your name or Company or the nominated Company name goes on the outer packaging. If you are selling in the EU then you require an EU RP resident in the EU and they must be printed on the outer packaging.
- Many clients ask if we can do one or both of these for them, we can certainly undertake this now that we have a separate Company to be able to do so.
So to recap…two portals, two RP addresses, both can be on the pack if the same product is sold here as in the EU. If your products have been developed by us then all the collating and inputting for Compliance in the UK happens automatically. We gather documents, reports and results obtained through you, put them in the correct format and then pass to our Toxicologist who undertakes the CPSR or Cosmetic Product Safety Report. If you also wish us to set you up on the UK portal we can also do this and also advise on the duties of the Responsible Person.
- The list of what we require to do undertake Compliance for you is or should be familiar to any other manufacturers you may be using.We need Safety Data sheets and Certificates of Analysis for each raw material, in fact we have a check list that you can ask them for…having explained what the potential use for them is then this requirement is self-explanatory.
- We will need the full formulation…yes it does need to be full not banded in most cases. The toxicologist will need to assess all the percentages to ensure that nothing adds up to more than legally and safely allowed.
- We will need Microbiological Challenge Tests…these are required to ensure that whatever level of preservation your formulators have chosen it is robust enough to keep bugs from growing and potentially harming anyone using the product. We can arrange this for you
- It will need Stability and Compatibility Test results…again these are very straightforward. It should hold together without falling apart or losing its consistency and going watery, or too thick to get out of the container, and it should ‘work’ in the packaging you have chosen…….So the lid or closure should ensure no leakage or seepage, if it’s a pump the material should come out as is intended and the material of the container should not affect the product and vice versa. Allingham Beck can offer this service
- We will need to see the proposed or actual label copy….. there are fairly strict rules for this one. The ingredients need to be in quantity of inclusion …so the most used at the top and the least at the bottom…. These need to be in the approved format and spelling. All allergens must be correctly listed…again a safety aspect since anyone with known allergies will be able to find these before using. The weight needs to be shown in the right sized print and the correct positioning. We can review artwork before printing and advise on any omissions
- Container detail…yes we need your supplier of whatever your product goes into to certify what the material is….ok now this seems a bit extreme but since there have been incidences of plastic leeching into product in the past it make sense. Also everyone is now becoming more aware of recyclability of materials so let’s face it, it’s been a long time coming and this industry has to clean its act up.
- Marketing Claims …this has to be dealt with on its own since its fairly major…..no claims can be made until they are substantiated …..say it improves lines and wrinkles and you have to prove it.
Say something is going to cure something and it’s a medicine and not going to be covered by Cosmetic regulations but even more stringent and far-reaching tests are required and not something we undertake.
No no’s….. yes that s right, you can no longer say no to anything so for example ‘no parabens’ or ‘not tested on animals’ …there is so much more to this one that I will need to write a whole blog for it alone to update it before long.
Needless to say, we can help with the whole CPNP Cosmetic Product Notification Portal set up and inputting, collating all the information above in a format suited to our Toxicologist and the CPSR, Cosmetic Product Safety Report that will ensue. We can also help with RP services both here at home in the UK and in the EU
I wrote this in order to try to de mystify the process somewhat and help answer the myriad questions I’m usually asked but if you need any further queries please don’t hesitate to get in touch