The subject of soap making legislation sometimes appears very intimidating for the individual and lots of people are put off starting their own soap making business as a result of this. However, the whole process is nothing more than a paper trail to verify that your whole melt and pour soap making process, ingredients, recipes and soap are safe. If there are any problems, they can be traced back to you and if necessary to a particular ingredient or batch. It is merely an audit system.
The legislation is not there to trip you up or catch you out, but merely to protect you and the consumer, i.e. your customer. It’s not enough to just know how to make soap, you just need to confirm that your products have been produced from a safe recipe, with good quality, reputable, safe ingredients, in a suitable environment. You need to be able to ensure, and to show that you have not knowingly used any process, or ingredients which could cause any harm or side effects to your clientele.
To meet these requirements you must to produce evidence that you used a consistent method and recipe, using the appropriate ingredients, in a clean and hygienic environment. You need to provide the following information about your ingredients:
- Details of Supplier
- Batch number of ingredients
- MSDS Sheets
- Chemical Analysis Sheets
- Gas Chromatography for essential oils
- IFRA certificates for fragrances
Each and every one of the above demonstrate that your ingredients reach a safe standard for cosmetic use.
You will need to provide your recipe, which will include ingredients, quantities and the method used to make your soap. You will need to prove that you consistently adhere to a Good Manufacturing Practice and you will have to provide details of this practice.
You will need to create a Quality Control System which will include a tracking system so that if anything goes amiss you can go back and identify precisely when the soap was created, what ingredients were included and which suppliers they were from. This will enable you to check all the other soaps that were created in the same batch to make sure there are no problems with them.
Once you have done all of the above you need to create a PIP – a Product Information Pack. This will contain all of the above information and will need to be submitted to a chemist who is qualified to certify your soap. For a fee, he or she will supply you with the necessary certification for your soap. He or she will be able to notify you about all aspects of the certification process, so it is worth contacting one early on in the process as help from them could save you a lot of time and energy. Much of this information exchange can be done by email these days, saving you time.
You will also need to label your soaps, describing your ingredients in the proportions in which they are included in your recipe, starting with the largest. The ingredients must be listed in INCI format. INCI stands for International Nomenclature of Cosmetic Ingredients and is an Internaional naming system which standardises the names so that they are internationally recognised. The requirements for exactly what information you need to display on your labels changes from time to time, so it is advisable to check what the latest legal requirements are before designing your labels and sticking them on all your soaps!!
Trading Standards also require you to sell soap by weight. There are two ways to do this – by average weight or by minimum weight. You need to discuss this with your local Trading Standards Officer as some prefer one method, and some the other. You need to display the weight either on the bar of soap itself, or at the point of sale. This means that in order to sell your soap by the slice, you can, for example, show the price by the 100g and then cut off slices, weigh them and price accordingly. Otherwise you can precut and wrap your soap and price it individually.
You will need to use accurate measuring scales for this. Digital kitchen scales are not considered accurate enough for this, so it is a good idea to discuss with Trading Standards how best to do this.
You will more often than not find that if you contact your local Trading Standards Officer, they will be only too happy to help you, as they like people who want to adhere to the law and they should be able to point you in the right direction to comply with the requirements.
Two more things that I’ve listed last, but are awfully important. You should not make any therapeutic claims on your products. You can only do this if you have scientific research to back up your claim!! There are many descriptive words you can use to sell your products, without making claims. It is worth discussing this issue with the cosmetic chemist as they can advise you.
You should also get some public liability insurance in case somebody has a reaction to your product, or, if you are having a physical sales point, rather than selling over the internet, you need to be covered in case someone injures themselves at your shop or stall.
So, once you have completed your paperwork and submitted it to the chemist, you can have fun wrapping and naming your products, so that you are ready to get going as soon as your products have been certified.