FAQ
What do I need to sell cosmetics legally in the EU?
The minimum requirements are a Cosmetic Product Safety Report (CPSR) constructed by a certified cosmetics safety assessor, legal labelling and claims check, the development of a product information file (PIF) and finally notification prior via the Cosmetic Product Notification Portal (CPNP).
What do I need to sell cosmetics legally in the UK FOLLOWING BREXIT?
You will need like for the EU to notify your product using the UKs ‘Submit Cosmetic Products Notification (SCPN)’ portal. As of April 1st 2021 the same rules and regulations within EU legislation apply in the UK with the only difference being the notification portal, responsible person needed to be in the UK and the PIF to be available at a UK established address.
What is a Product Information File?
Contains all information in hard or electronic format for demonstrating safety and legality of your cosmetic.
What testing will I need prior to legal sale of my cosmetic?
In general, depending on the product you will need stability and possibly challenge (preservative efficacy) test data. Most stability work can be concluded from 3-6months of accelerated stability testing. This form is testing is carried out at specialist labs which Legal Cosmetics® can introduce you too if required. This data not only forms part of the CPSR but also the shelf life / period after opening data. Tests are generally conducted according to ISO 18811:2018 and can take into consideration normal conditions of use including storage conditions.
The challenge test takes into consideration ISO 29621 and thus the type of microorganism that maybe introduced into the product through normal uses (i.e. placing your finger into a cream). Carrying out testing to international standards (i.e. ISO 11930:2019 or USP 51) are needed for a robust CPSR file. Both stability and challenge testing will assess a number of end points including levels of microorganisms and retention of the products physical, chemical and organoleptic properties over its shelf life.
Is food grade packaging ok for my cosmetic?
Packaging is a key component of the final products safety and in accordance with the cosmetics regulation information will need to be provided on potential leaching from the packaging. Thus we need to consider not only the cosmetics regulation but REACH (plastic materials etc), packaging and waste legislation (Dir 94/62/EC) as well as more general product safety rules (Dir 2001/95).
What is the impact of changing my ingredient supplier?
The main considerations are changes to the formulation on an ingredient by ingredient basis. If your supplier is a patented formulation that cannot be provide by another manufacturer then you must consider the toxicology based on the amount of x ingredient or its purity has changed. In this case consideration over the impact on the products safety should be considered and discussed with the Legal Cosmetics® team.
How has Brexit impacted my products legal sale?
The UK trading association for cosmetics manufacturers has some good information on their website https://www.ctpa.org.uk/no-deal-help
The safety assessments prepared by Legal Cosmetics® will be valid for selling in the EU and UK. Draft Statutory Instrument (SI) issued by UK government regarding Cosmetic Regulations post-Brexit show the same safety requirements as the EU and deviation is not expected, to allow continuing cross-border selling. EU have advised safety assessors to ensure their UK-based qualifications can be shown to be equivalent to qualifications in an EU member state, and equivalence has been confirmed for qualifications obtained in the UK by Dr Mark Tallon, LLM MA PhD CSci FSB FRSM.