Are my cosmetics safe?

How safe are your cosmetics?

 

When you purchase a cosmetic product- including cleansing products in the UK - one assumes that it has passed all the regulatory hurdles, that it is safe to use for you and your family and that what it says it contains is actually what it contains.

If you are interested in the behind-the-scenes regulation of the UK cosmetics market, then read on - or indeed if you like to be reassured about what you buy then also read on! As a heads up, this may be useful to anyone looking to bring a new cosmetic product to market, but less interesting for everyone else!! In short for everyone else – the products you see on the shelves of your local supermarket or indeed local craft fair, have jumped through rather extensive regulatory hoops and you can assume are safe to use. You do of course need to be aware of allergens (if you have allergies) and these should all be clearly labelled on packaging. You may also want to be cautious of potentially irritating or harsher ingredients if you have sensitive skin or skin conditions. These can be things like sulphates (not all sulphates are harsh, but ones like SLS and SLeS are known to be harsher than a lot of other cleaners) and phthalates (which endocrine disruptors and are regulated, but, particularly if you are pregnant or being extra careful about your health, might be best to avoid them full stop). For more info on phthalates, read more here. We are of course sulphate and phthalate free.

 

For anyone else looking for more in depth info on what it takes to bring a cosmetic product to market, please read on!

I haven’t included information about products with nano materials or imported products as I have no experience of these. Aerosol dispensers, candles and room sprays also have different regulations to which I know nothing about and are not included here. It is the Office for Product Safety and Standards which sits within the Department for Business, Energy and Industrial Strategy who is responsible for the cosmetic laws.

 

In a rather large nutshell to comply with UK regulations to sell a cosmetics product on the UK market you need to:

1. Obtain a Cosmetics Product Safety Report – this includes information about where the product is manufactured, details on all the individual ingredients including their batch numbers, formulation and allergy information.

2. Obtain a Product information File (PIF) - this must be kept up to date and available to market surveillance and enforcement authorities when asked to do so. 

3. Nominate a responsible person for your product who then registers your product on the government portal known as SCPN  - Submit Cosmetic Product Notification service.

4. Ensure your product is made following Good Manufacturing Practice (and obtain the statement to confirm this). If you are not manufacturing the product yourself,  it is important that you find a reliable and trustworthy company to make it for you.

5. Log the batch number of your product and have this on your packaging.

6. Comply with labelling regulations for example  a full list of ingredients, registered address, allergens - this needs to apply to INCI regulations,  weight of product, batch number etc.

 

In more detail I will, as briefly as possibly, describe the above processes 1-6 and how to undertake them.

1. Obtain a Cosmetic Product Safety Report

Every product on the market has a CPSR report which is held by a nominated 'responsible person’. This report includes a list of ingredients, a write up about all ingredients including their properties and why they are safe, calculations of ingredients which include NOAEL (no observed adverse effect level)  and SED ( systemic exposure dose) calculations, images of the product, safety documentation and traceability of each raw ingredient, IFRA (International Fragrance Association) statements. A CPSR can only be

written by people who hold certain university qualifications which include in toxicology, pharmacy, medicine or similar.

  

2. Obtain a Product information File (PIF)

This must be kept up to date and made available to market surveillance and enforcement authorities when asked to do so. For more information click here.

  

3. Nominate a responsible person

This person is responsible for registering your product on the government portal. The responsible person is someone within your company who takes on the job of overseeing all the regulatory hurdles. In our case, this responsible person is me – Tina!

 The responsible person myst notify each product to the Office for Product Safety and Standards (OPSS) commonly known as the Cosmetics Portal. As an extra incentive the home page on the government website clearly states in bold that:

 ‘You may face a fine and a prison term of up to 3 months if you do not notify the OPSS about a cosmetic product. This fine could be unlimited in England and Wales or up to £5,000 in Scotland and Northern Ireland’

The ‘Responsible Person’ must make sure that their contact data remains up to date - in theory the responsible person should be available should anyone have an adverse reaction to your product. That way, people treating that person will have immediate access to what is in the product and where it was sourced. It is also useful for epidemiological tracing.

Your account set up through this government portal includes details of all the products that you sell, name and contact details of the Responsible Person.

Each product notified is given an UK cosmetic product number. You have to declare whether your product  is specifically marketed for children under 3, list all the ingredients and upload an image of the front and back of your product along with its name and reference number. You have to declare whether it has CMR substances in it  - carcinogenic, mutagenic and reprotoxic chemicals (we don’t have any CMR substances by the way) and give a description and what it is to be used for.

 

4. Good Manufacturing Process.

While our product is made elsewhere in the UK, for government regulatory purposes, if the product is manufactured to your specification and has your trademark on it then technically you are the manufacturer. It is extra important therefore if you are not making the product yourself, that you trust the company who is making it. The list to follow for good manufacturing process is too long for this blog, click on the link above however and you will see a comprehensive list as specified by the UK government.

 

5. Each new batch needs a new Batch Number.

Each batch will also have different raw ingredients whose individual details and batch numbers you have to document and retain

In your PIF. As you see, the PIF is a dynamic document which needs to be kept up to date.

 

6. Packaging labelling regulations .

Legally, the manufacturer is obliged to put certain things on the packaging, such as weight of product, ingredients, allergen, use by date and use of product – if not obvious. The above is not exhaustive and clicking on the link will give you an exact list. One practical trick to remember however - when your printing company gives you an excellent price for an extra 500 or 1,000 packages - be wary of accepting. Things change and for your next batch of product you might be unable to source an ingredient, or the list of declarable allergens will change. You are then faced with a lot of beautifully printed but incorrectly labelled packages. We learned this the hard way….

 

A side note on IFRA (International Fragrance Association).

80% of the big perfume manufacturers are members of IFRA. As a member is it mandatory to follow their regulations.

For other smaller companies like us it is advisable to adopt the IFRA guidelines.Their latest (51^st) document on allergens has over doubled the number of allergens to be documented on the packaging from their previous – 50^th document. Again, another good reason to keep your printed packaging and batch numbers small – allowing for low-cost flexibility.  

 

The above sounds a lot to do and it is for a small company. Obviously the bigger the company the more people you can delegate such tasks to. Some things have to be paid for such as the CPSR as this needs to be done by someone with appropriate certification – other things are easily done by yourself – they just need time. If you are a small company starting and require some help, then do DM me on Instagram or send an e-mail. I’m not an expert but I have gone through this laborious process a few times now and will try and point you in the right direction if I can.

 

 And finally, after doing the above, as well as the other parts of a small business – registering at Companies House, insurance, sourcing raw ingredients …. It’s all a waste of time unless you are able to sell the product, so do your market research first and make sure there is a real need for what you are intending to produce!