What does the European Hygiene & Cosmetics Regulation mean for soap makers?

In addition to getting set up as a lawful soapmaking enterprise, it’s important that your products comply with all relevant European Union directives and statutes. In this blog, we examine the cosmetics regulation (because soap is a cosmetic product after all), as well as the cosmetic product safety reports (CPSR) and the reason why they’re so important. If, in today’s world, you want to make, market and sell soap, it is extremely important that you observe the European Hygiene and Cosmetics Regulation. If you don’t, you could end up in serious trouble.

What does this regulation entail?

The Hygiene & Cosmetics Regulation ensures that – throughout the whole of the EU – all cosmetic products available on the market are safe and suitable for their intended goal.

EU regulation (EC) no 1223/2009 It is a serious offence to supply a cosmetic product that can harm human health or contains substances that are specifically restricted or prohibited.

This law has existed for quite some time, but it is constantly being revised and adjusted. As a soap maker, you are legally obliged to ensure that the products that you make, gift or sell comply with the most current version of the regulation. It is also an offence to withhold certain safety assessments and technical documentation. This means that the contents of your soap products – i.e. the raw materials and ingredients – must be assessed and certified as safe and that you keep suitable records of these.

Do your products comply with these directives and statutes?

 The EU directive is being enforced more and more strictly in all European countries. This directive defines cosmetic products as ‘any substance or compound that makes contact with external parts of the human body (skin, hair, eyes, nail, lips, etc. This especially involves products that add scent, cleanse, bathe, condition, protect or counteract body odour)’.

As a traditional soap maker, you must be able to prove the safety of your product(s). You must therefore have a product information file with a safety report containing product information and an assessment, all of which must be submitted to the regulatory authorities. The assessment is based on the toxicological properties of the substances in your soap product, and on results of exposure to the product. The safety report contains e.g. the ingredients in the product and a description of its intended use. With this report, the producer states/declares that the product is safe for consumer use.

Your labelling must be compliant. According to the law, all bath or soap products must be labelled. The label must feature the product function, name & address of the manufacturer/importer, volume, directions for use & warnings, country of manufacture, batch or code number, use-by date and ingredients.

Your production area must also comply. The production of cosmetic products must take place according to Good Manufacturing Practice (GMP). Within this context, the NVWA applies the NEN-EN-ISO 22716 standard. GMP requirements include quality control (water quality and handling of ingredients), production (organisation, premises, machinery, etc.), product packaging, storage, hygiene, documentation and handling of complaints.

If you really want to make soap but reckon this is all a bit complicated to handle on your own, we highly recommend that you sign up to the EU Soap Quality System (SQS). It’s an affordable and efficient system that ensures compliance with all the rules and regulations. Once you meet the conditions, the SQS will assume responsibility for your entire production process so that you can focus on your preferred activity, i.e. soapmaking.

EU Soap Quality System (SQS)
Hofmanweg 41
2031 BH Haarlem The Netherlands

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