A couple of days ago I went on a day course to learn all about the legalities of selling cosmetics in the EU. I found it very interesting and thought, even if you have no intention of ever selling makeup or toiletries, other people might at least like to know the effort brands go to to sell their products.
There's so much information that this is not going to be comprehensive by any means but it will give you the basic idea of what's required.
After reading this I think it will make it clear why there are so few indie cosmetic companies operating in the EU! Firstly the costs are prohibitive and secondly there is a hell of a lot of paperwork involved! (and I'm not even going into trading standards or any of that irritating stuff as it's not specific for cosmetics).
OK so while you might think making cosmetics at home would have rules similar to making food products at home it isn't. With food the regulations mostly apply to you (needing to get certificates in hygiene and so on) with cosmetics it mainly applies to the safety of your products with less interest in you. You do however need to make a Good Manufacturing Policy (GMP) which contains information such as where you intend to make your products, how you will ensure proper cleanliness, how you will take efforts to keep supplier information (such as batch numbers of ingredients in case you come across a problem) and so on. This is an official document which you must sign as a promise to comply with what you've written. When Trading Standards check you out they will check out your work area and stuff but I think otherwise you're just trusted to be sanitary (it's in your best interests anyway, noone's going to want to buy from you if they find dirt/hair in your products!)
So as I said the main regulations are surrounding your products, and this is where it gets expensive! Every product you make needs to have the recipe assessed by a cosmetic chemist. Each go will be around £150 but that's an estimate. Now when I say every product I don't mean that if you have a line of moisturisers with the same recipe but different scents they will all have to be tested there's some leeway. You can get away with making moisturisers with different scents and slight changes in ingredients (such as different oils or butters used) as it will make little difference to the recipe anyway. But if you wanted to start a toiletry range then you'd need different assessments for your soaps, creams, scrubs, and so on. If your recipe is found to be unsafe (though it's unlikely if you've done your homework) then you will not get your money back and you will have to have it assessed again when you've made changes to the recipe.
Right so once you've have your formula safety assessed you might think you're good to go. Not so. If your chemist suggests it you'll have to supply samples of your product and send it for 'challenge testing'. This is likely to only be for products that contain water and so MUST have a preservstive (some girls on the course were basically shuddering at the idea of using a preservative because they were so focussed on the idea of being 'all-natural' but I don't understand that mindset. To me it's better to use something, even parabens, that may be slightly frowned upon as a naughty chemical substance that have an unpreserved product that will harbour bacteria, grow mould and possibly harm your health). Challenge testing involves the technicians messing with your product, exposing it to nasty things and testing the bacteria levels to see if your preservative is strong enough. This will take about 6 weeks and costs around £200 a pop. And again if it doesn't pass then you have to go through it all again. Yay!
That luckily is where the product testing ends but there's still a lot of rules to follow. Labeling is a huge thing with very strict rules to follow. You also need to keep a document called a Material Safety Data Sheet (MSDS) for EVERY ingredient you use. Luckily you can find the MSDS's for most things by googling or you ask your suppliers for them. With fragrance oils though you MUST get them from your supplier because they change dramatically.
And finally for each batch of product you make you need to keep a manufacturing log including the weights, date of manufacturer, method of manufacturer, batch number and so on.
Phew! There's more to it then what I've described of course but that's the basics and you can see how rigid and difficult they sound. However I do actually think this is a better system then they have overseas because it really shows that you can trust the sellers and their products so we have far fewer Glittersniffer type horrors over here.
I hope you found that interesting. If not then here's a picture by way of apology:
