# Entering the murky world of EU regulations



## The Efficacious Gentleman

If "y'all" in America think you have it bad, there are some impressive hoops that we have to jump through in Europe to sell soap!

I'm a long way off selling, but I think I'll get started on it now as it is really in depth, even for a craft-size business :sad:


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## The Efficacious Gentleman

Here is a nice sample from the guidelines for safety tasting of cosmetics - 

3-3.3 Molecular weight 
The MW of each substance should be given in Daltons. In the case of mixtures, the MW 
must be given for each of the constituents. 

Might have to print this out and pour myself a glass of port to get through it.


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## MirandaH

My husband and I just had a baby and he doesn't want me to go back to work, so he dropped some money in a separate bank account for my soap and took the list of things I wanted to buy for a HOBBY I really wanted to TRY (without even asking or discussing it) and went out and bought enough oils to cook for an Army and came home and said "If you want to do soap, why not try to make this your stay at home job?" He bought all the stuff I would need except FOs, EOs and colorants. I don't even know how he got out of the hardware store with 12 pounds of lye, but he said that no one asked any questions.  I am absolutely terrified and want to take things slow so I get everything right and understand the legalities of everything. He is disappointed with curing times and thought this would be like when he started his business (which was an overnight success).  

I have a Bachelors in Legal Studies in the US and even I don't want to think about what you are reading.  Good luck in your studies.  I'm not brave enough to even look at everything required here and probably won't in the next year, unless someone wants to buy my soap, in which case I will probably talk myself out of it completely.


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## neeners

oh geeze, that sounds like you're going to have some heavy reading to do in your near future, Gentleman....  good luck with the studying, and hope you have a LOT of port.....

MirandaH, I think there are stickies in the CP section, and I believe there are soap guilds in the US that are available to help.


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## Lindy

Have you chosen your Safety Assessor yet?  They can be of huge help if you get the right one.  http://www.cosmeticsafetyassessment.com/ This company has a huge following because Scott is so helpful and easy to work with.


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## MirandaH

neeners said:


> oh geeze, that sounds like you're going to have some heavy reading to do in your near future, Gentleman....  good luck with the studying, and hope you have a LOT of port.....
> 
> MirandaH, I think there are stickies in the CP section, and I believe there are soap guilds in the US that are available to help.



Thank you Neeners.  I will be sure to check when I am ready.  For now, I am just trying to come up with a good soap recipe.  At this point, I am only 5 batches in and 3 are Castile...it's the hubs that is in such a rush. :crazy:


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## The Efficacious Gentleman

It doesn't seem like they do Austria - so I'll get my registration for the product information system sorted out and then work with them to find a good SA in the area.  But thanks for the link, though


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## Twiggy

Hi The Efficacious Gentleman!  I’m going through that process myself, and if I could advise you – get an Assessor!  U will not make forward without being analyzed! As for EU citizen, from 07.2013 you have right to choose any Assessor from UE. So Scott probably does Austria, but law is one think – life is another. I’m not sure if Austrian authorities will accept UK Assessment as full service you need to get to next step of “paper work”… I can recommend you one from Germany – I’m working with them right now. They have very kind and friendly approach  If you interested pls let me know, I will be happy to share that info with you


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## AtraGarden

Procedures everywhere! This is how they keep bad away from good. I really get annoyed sometimes but nothing we can do about it. Keep on reading Gentelman


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## Twiggy

AtraGarden said:


> Procedures everywhere! This is how they keep bad away from good. I really get annoyed sometimes but nothing we can do about it. Keep on reading Gentelman



That’s right! Is pain, for good reason – other story is the cost of this FUN… Jus ridiculous in Europa!


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## The Efficacious Gentleman

I can understand regulation, that is for sure - I wouldn't want to use a dodgy product on me, I want to know that I what I buy is safe, so I have no issues jumping through the hoops for my part.

Twiggs, I would love the info on that assessor.  What does the assessment consist of?


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## Saponista

I'm looking at all this too, any idea how to work out a proper 'best before' date for your soap? I can't find anything online about how to do this. I guess a cosmetics assessor would help but I wanted to have a good idea about what was involved and be really organised before even contacting an assessor.


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## Twiggy

@The Efficacious Gentleman
The basic assessment includes theoretical work on your ingredients. So you will be asked to fill out some forms and present the methods which you use to manufacture you soaps, and form with the recapture itself. Than some  microbiological results of plant parts if you use them – like lavender and so on. But they provide such service, if your supplier will not have those details (and probably they will not) the assessor will run such test- I think it will cost not more than 100E on the top. You must know the weight of your end product, they may ask you to send labels, but also help you to create a correct one – again for a payment.  You will need to specify shelf life of your soap. I choose to put the open dose sign with the 12 or 18 months on it – I think is the safes one. But the most important will be the safety data sheets of each product! So is good to start to collect them right away, when you find your supplier  But that not the end – you must have a separate kitchen, easy to keep clean. That kitchen must be control and approved by one of the offices in your area. There is some serious work to do in the town with local authorities offices to get approval to produce cosmetics in your home. Basically there is no difference between you and L’Oreal for example. The same rules! For instance in UK is possible to use the same kitchen – no problem. In Germany the place of you manufacture can be checked by some kind of officer, food safety or something… So is a lot of to do, and to consider…  And is HELL EKSPENSIVE!
There is a link for the whole procedure, I’m very sorry all of you but is in German:
http://blog.seife-selber-machen.com/2012/09/17/naturseife-selber-machen-und-verkaufen/
That may give you better overview on that matter. 
@ Saponista
the good place to be is www.facebook.com/pages/Guild-of-Craft-Soap-Toiletry-Makers . Scott is very helpful, and other sopaers sometimes also are willing to help Sterat from there, and dig, rummage and look in internet – there is no other way!


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## Yill

Hi everybody,

I just posted a similar question on another part of this forum but Gentleman was so kind to direct me this way 

Will be reading this topic and hope I can contribute to the info giving part, although I'm just starting to read into this myself.

Thanks so far


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## Yill

Twiggy said:


> @The Efficacious Gentleman
> But that not the end – you must have a separate kitchen, easy to keep clean. That kitchen must be control and approved by one of the offices in your area. There is some serious work to do in the town with local authorities offices to get approval to produce cosmetics in your home. Basically there is no difference between you and L’Oreal for example. The same rules! For instance in UK is possible to use the same kitchen – no problem. In Germany the place of you manufacture can be checked by some kind of officer, food safety or something… So is a lot of to do, and to consider…  And is HELL EKSPENSIVE!



I don't understand why there are different rules for the same EU law in different countries. So if you live in the UK you can make soap in your own kitchen and the law considers it safe and if you are in Germany like you are, it's not? MG that's just nuts!


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## Twiggy

That sad, but true... Especially that soap is not rocket since! It must be safe, not doubt about it, but why they make it so difficult I don’t know. Plus lots of women who raising children and would love to stay at home with them, could run little home business and be happy mam and earn money.


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## Lindy

In Sweden they require a additional 1000 GBP (I think that's the number) from you annually just to run your business.


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## The Efficacious Gentleman

I personally don't see how they can say it's not safe to make it in a kitchen - we're talking about the product safety here and I like to think that there is nothing there that would make the soap bad!  If it's more about it being safe for cooking AFTER making soap, then no matter where I make it is going to be soaking wet in lye solution according to that logic, and so no where would be safe!

Alas, there are a lot of differences in how the EU regs are applied over the world.  I am struggling to find a decent resource for who/what are actually able to be a safety assessor, so I can't find an Austrian firm as yet.


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## Saponista

I don't understand the kitchen issue either, in the uk if you want to make food products you have to have your kitchen assessed for safety and hygiene even if it is in your own home. I don't understand why you can't just do the same for soap making.


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## Twiggy

That the quote from other thread  EU regulations - help needed!, maybe we should move all to one 



The Efficacious Gentleman said:


> Out of interest, Twiggy, why does it have to be another kitchen? I have a cellar with a sink with water and electricity to run my slow cooker for HP soap, plus a window to open for air when I need to. Could I technically do it there?
> 
> Washing up would be in the kitchen up stairs, but then that is just washing up.................



Efficacious Gentleman, Saponista,  is a very good question, and I don’t know the answer “why”…  Thinking logically “HOMEMADE COSMETICTS” may be produced at home, but in Germany you must have “Werkstatt” 
And that’s what I’m going to do as well, I will have my soap kitchen in “wash kitchen” in the cellar. In here you have to have running hot tater as standard for such a kitchen (for soap manufacturing) as well… But according to regulations in my “land”. Plus in my case I have to renovated it and arrange it as kitchen, as for now is only old sink and laundry machine plus OLD and UGLY, DIRTY tails on floor and walls – my cellar is like from horror movies to me LOL



The Efficacious Gentleman said:


> I personally don't see how they can say it's not safe to make it in a kitchen - we're talking about the product safety here and I like to think that there is nothing there that would make the soap bad!  If it's more about it being safe for cooking AFTER making soap, then no matter where I make it is going to be soaking wet in lye solution according to that logic, and so no where would be safe!



Exactly what I think about it!!


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## Twiggy

And here (again in German – sorry guys) is the process of making soap legal. You can see how that kitchen looks – nothing fancy, but it must be done. And don’t look at the prices for assessment, now is over 4 times more :crazy:
lissi.novemberkids.de/index.php/projekt/


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## The Efficacious Gentleman

Looks good (leider Deutsch ist nur eine Fremdsprache) 

My cellar has cold running water, but over the hall is a room with hot water, too.  Annoying.


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## Twiggy

The Efficacious Gentleman said:


> Looks good (leider Deutsch ist nur eine Fremdsprache)
> 
> My cellar has cold running water, but over the hall is a room with hot water, too.  Annoying.



"leider Deutsch ist nur eine Fremdsprache" Yea, mine too! And I’m really sorry for that German stuff, but that’s all I could find, and I need, as I will work with offices and rules in Germany. Maybe Saponista will come up with something in English texts, but again it will be rules only for UK than... Is hard to find any info about such things!

In my kitchen is also only cold water, but luckily we have a plumber as a good friend, and he will work on that issue  You can buy an electric water boiler, to have pro forma is ok I think, only to have in a case of control – but first u must be sure what the regulations in your area are and if you really need it!


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## The Efficacious Gentleman

True - again, I would seriously question why hot water is needed, but as a question that will just bounce off of an EU beaurocrat like a rubber ball off of a mountain!

Count yourselves lucky, Americans!  Land of the free, indeed.


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## Saponista

That's for hygiene reasons I think, so you can wash your hands before preparing things. I imagine the regulations cover a wide range of handmade cosmetics and face creams, lotions etc. all need to be made in a sterile environment.


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## The Efficacious Gentleman

But then they know nothing of making soap - I might have pee all over my hands (I don't!) but there is no way on this earth that my hands are going in to raw soap batter.  Even with lotions and so on, they are heated to kill the germs and then a preservative is added in.

It seems like one of those things that someone in a committee meeting puts in because it sort of makes sense - clean hands for making something like a face cream - with out thinking if it is actually handled in that way.


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## Saponista

Exactly, that committee have made some wide all encompassing rules that make doing anything impossible without considering that things should be different for each type of product made.


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## Lindy

And people in Canada complain because we have to register all our recipes with Health Canada for free.  Whatever, I am glad we aren't as regulated as you are in the EU....


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## Twiggy

Lindy said:


> And people in Canada complain because we have to register all our recipes with Health Canada for free.  Whatever, I am glad we aren't as regulated as you are in the EU....


Lindy, I’m so jealous that is so much easier for you guys than over here… You can have 10 different soaps in you little store, your imagination set limits, here 10 recipes is a serious investment of some thousands Euros :\


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## Saponista

In some ways I don't mind it being more difficult in the EU as it means there is less competition for budiness.


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## Lindy

Would you believe with how easy it is to comply here there are a lot of soapmakers that don't bother?  It's why we started the association, to try and raise the standards a bit and be seen as a professional craft rather than just a hobby craft.


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## Twiggy

Aaaaaaaa, Lindy, now I know how you r familiar with Scott from Guild of Craft Soap & Toiletry Makers! He is amazing, and that’s very good idea to provide such "service" or membership for serious soapers! I couldn’t agree more!
How far are you with the project if I may ask?


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## Lindy

Hi Twiggy - yeah I'm on Fresholi so know a lot of EU soapmakers.

The Association is up and running and we have vendors offering discounts to members too, so although we're still really small, it is coming along.


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## Twiggy

Lindy said:


> Hi Twiggy - yeah I'm on Fresholi so know a lot of EU soapmakers.
> 
> The Association is up and running and we have vendors offering discounts to members too, so although we're still really small, it is coming along.



SUPERB! O well the long journey must start from small, first step! You will get more recognizable with the time. And cooperation with vendors is brilliant idea!  What can I say – GOOD LUCK!!


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## Lindy

Thank you Twiggy


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## MirandaH

The Efficacious Gentleman said:


> True - again, I would seriously question why hot water is needed, but as a question that will just bounce off of an EU beaurocrat like a rubber ball off of a mountain!
> 
> Count yourselves lucky, Americans!  Land of the free, indeed.



Ha!!  Depending on where you are in the US, it seems.  I can't even get into what is required of a soap maker here in the states, or even my state, because unless I can afford to rent somewhere to make soap, I can't own a business from home.  Well, I can, but I need permission from the landlord and then if I can get that I have to follow these rules for my city (this is to run ANY home based business in any area zoned residential) which include not keeping any equipment on the property and "There shall be no on-site sales to the general public *or products or merchandise.
*"

I called to clarify, and they will not allow you to keep any product on site either.  So I have to pay to have it stored somewhere else.  They call it your "Commissary" and you have to get paperwork from another business saying they have agreed to rent you space and the city can come and inspect the area at any time. Your equipment must also be kept there. Oy!!!


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## The Efficacious Gentleman

I feel your pain!


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## Tienne

How can it be a home-based business if the business it isn't allowed to be at home! Stupid bureaucrats!


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## Twiggy

Miranda, I hear you here! My God! So not only Europa is going crazy about it  To be honest, I would love to have UK regulations for assessment and business


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## MirandaH

This was a big compromise on the city's part.  Before allowing a Commissary, you just could not have a home based business at all.  But with the invention of the internet, the people threw a fit about wanting to have websites where they could sell things from home, so they come up with this mess.  

There are loopholes to everything.  As long as the products are not finished and packaged for sale, they can be at your home (provided that no one driving by can tell there is a business in your home at all.  You cannot store ANYTHING outside or do anything outside, so I can't store my dirty equipment outside like I have been).  What you have to do is keep your equipment and supplies at your Commissary.  When you want to soap, you go get your stuff and bring it home and soap to your hearts content and then take all of your stuff back to your commissary.  As long as the soap is still curing, it is not technically finished and I can keep it at home.  Once it is packaged for sale, it must be at the Commissary.  So theoretically, I could just leave the soaps on the drying rack until they sell online and then just package them up and send them out.  No on-site sale, just internet or deliveries to people's homes.  If I were to do a show, I would have to be able to package it and take it to the Commissary and be able to get into the space I am renting to pick everything up for a show and take it and then drop the leftovers back off before I go home...or unwrap it all and put it back on the drying rack (not going to happen). Your Commissary can be a storage unit, but it would have to be temperature controlled.  A storage unit would get me around having to be able to get in at 3 am to take them to shows where you have to set up early. 

In addition, you cannot increase traffic, by road or foot traffic.  You cannot have USPS, UPS or FedEX show up at your house more than once per day each to pick up deliveries and you cannot, under any circumstances, allow anyone to soap who is not immediate family, living in the residence. 

Again, this is for ANY business in my town that is run out of the home.  I haven't even gotten into requirements for soaping, itself. This is why I didn't even want to look.  But I am glad I am checking it out.  Seems if I started now, I might be ready when I am ready to sell, which is a long way off.


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## Yill

I've had contact with cosmeticsafetyassessment.com in the UK to see if they can help me out. They can definitely do the assessments and told me what my other steps would be. I would like to share this with you, so here's a part of the email they sent me:
"As well as the assessment, you will need to label you products correctly and maintain the PIF paperwork. If you proceed with us I can send you some information on that. You will also need trading standards approved scales in place. You should also have product and public liability insurance. Although not a legal requirement, it is also worth letting Trading Standards know about your business, they may have other requirements that you need to comply with. Finally, you will need to register at the central portal http://ec.europa.eu/consumers/sectors/cosmetics/cpnp/index_en.htm. We have a guide for that too."

They can help you with all these steps, but I have to find out what Trading Standards is in The Netherlands.
Just like Miranda I'm not ready to sell yet, but by the time I've figured this all out I might be!


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## Twiggy

Thanks for sharing Yill! But before you take out assessment in UK, check with the “food and health department” in your area or something like that, if the will accept assessment which is slightly different than it may be in your country.  If I remember correct from cosmeticsafetyassessment.com you will get kind of allowance to work on some ingredients in CP soap area? Or how does that work?


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## The Efficacious Gentleman

I'm with Twiggy - speak with one who is in country as they will know what is required.  UK is easier than Germany, for example.  I'm hoping that Austria is the easiest of them all...............

Here is a page with some contacts in country - only 1 for NL, but has both English and Dutch!

http://csa-cosmeticsafetyassessors.weebly.com/list-of-cosmetic-safety-assessors.html


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## Lindy

Your SA is good across the EU as that doesn't change, what changes is your trading standards and other regs required by your country.  For instance in Sweden there are additional annual charges that the government has put into place in order to run a soap business.  As Twiggy said Germany has its own requirements for what is required to run your business.  But the SA itself is the same because that is required by the EU agreement.

 My understanding is that Scott will work with you to create a SA that allows you to versatility in your formulation I CP assessment.  He used to do flex assessments but I'm not sure anymore.  He also has some assessments that allows you to make lotions and he gives you the formula plus indicates how it must be packaged to remain within the legalities of your SA.


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## The Efficacious Gentleman

Lindy, you would be very surprised at how often the EU regulations vary in their implementation from country to country.

The example being that you can get your safety assessment (for the process rather than the ingredients) when you make soap in your own kitchen in the UK - in Germany you need to have a different kitchen for soap than for food.

If your assessor knows this, great - but they may not know the ins and outs for all the countries too well.  In reverse, someone in the UK using a German assessor might well end up making a second kitchen when they don't actually have to, while someone in Germany using a UK assessor might well not do it as they were told it's not required.


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## Lindy

Yeah I've heard the implementation varies country to country.  I know one lady in Italy and she had bunches of hoops to jump through but they also have grants available for soapmakers to help with the equipment.  The only other 2 I'm aware of (besides the UK) are Germany and Sweden.  It just amazes me how different the implementation is.  I had thought that it was trading standards that made the implementation standards but not being there, I really don't know.  I just know what I'm told on Fresholi.....


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## Twiggy

Lindy, in Germany you mean something what was discussed already here, or something new? I swear me patient is tried here with more and more obstacles


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## Lindy

No here and on another forum that doesn't exist anymore about how you have to have a separate room for soaping.  You have a lot of obstacles and hurdles in your country.


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## Twiggy

Lindy said:


> No here and on another forum that doesn't exist anymore about how you have to have a separate room for soaping.  You have a lot of obstacles and hurdles in your country.



:-( I know Lindy - thank you for answer. I'm already registering on Fresholi  There may I will find some more information. But also, people from Germany don't share it gladly, so I will see!


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## The Efficacious Gentleman

Just sent emails to two Austrian assessors to find out what the road ahead looks like.  As I said, I am a long way away from selling, but I need to know where I am aiming for at least in general.  For example, if I build all of my recipes with lard and then find out that I can't use it - just as an example, I have no idea if that is the case or not.

Also registered on Fresholi for info on the assessment.


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## Twiggy

That’s very good thing to do!!!! From then you can start to build the plan  Good luck with your journey!! Good luck to all of us hehe


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## The Efficacious Gentleman

Alas I just heard back from one of them - they want 600€ just to get the ball rolling.  I'm not able to spend that much money for them to clarify the requirements and find out that there is no way it's possible at this point.

Will wait to see what the other one says


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## Saponista

That's a rididuculous amount just for some information! There must be a regulatory department in your country who upholds the rules, equivalent to uk trading standards. If you can find out who they are you could probably go direct to them and find out exactly what their inspectors check for when they come to check if a business is legal.


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## Twiggy

The Efficacious Gentleman said:


> Alas I just heard back from one of them - they want 600€ just to get the ball rolling.  I'm not able to spend that much money for them to clarify the requirements and find out that there is no way it's possible at this point.
> 
> Will wait to see what the other one says


So the Assessment Company want 600E just to start working with you, I think I didn’t understand this right...


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## The Efficacious Gentleman

Twiggy said:


> So the Assessment Company want 600E just to start working with you, I think I didn’t understand this right...



No no, Twiggy - you're spot on!  He said as a freelancer he's had bad experiences where people have taken information and then gone elsewhere.  But to be honest there is no way I'm paying anything until I know what I will be paying for.

Heck, even if it's just a link to a decent run down of the Austrian requirements.

Sappy, I think there will be - just need to get over the language barrier and get hold of someone.


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## Twiggy

The Efficacious Gentleman said:


> No no, Twiggy - you're spot on!  He said as a freelancer he's had bad experiences where people have taken information and then gone elsewhere.  But to be honest there is no way I'm paying anything until I know what I will be paying for.
> 
> Heck, even if it's just a link to a decent run down of the Austrian requirements.
> 
> Sappy, I think there will be - just need to get over the language barrier and get hold of someone.



I wonder how much clients he won with such politics!?  Don’t worry, in the worst case, use contact you got from me – they already give me a lot of info – I have my all ingredient check with them, so basically approved for assessment – and until now I didn’t pay a penny! Plus I’m pretty sure that German SA will be as much valid as Austrian in Austria


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## Yill

That really is a LOT of money Gentleman!
The people from the UK I mentioned earlier are really nice and helpful. They don't know all the rules that would apply in The Netherlands however, so I'm going to try and gather as much info as I can and then probably let them assess my recipes. 

I was wondering, what if we make sure we got our recipes assessed, get the labeling right, get our insurances in order and just start selling? Would they really go and check if you have a separate kitchen? It just seems to me that if you do everything by the book as far as safety (for your costumers) concerns, the rest is just bureaucracy :roll:


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## Twiggy

Yill said:


> That really is a LOT of money Gentleman!
> The people from the UK I mentioned earlier are really nice and helpful. They don't know all the rules that would apply in The Netherlands however, so I'm going to try and gather as much info as I can and then probably let them assess my recipes.
> 
> I was wondering, what if we make sure we got our recipes assessed, get the labeling right, get our insurances in order and just start selling? Would they really go and check if you have a separate kitchen? It just seems to me that if you do everything by the book as far as safety (for your costumers) concerns, the rest is just bureaucracy :roll:



In Germany (and I think it works similar in all UE countries) you need to get registered by competent administrative authority (district office, possibly the mayor's office), competent Chemical and Veterinary Investigation Office and Federal Office of Consumer Protection and Food Safety. I think the third one having officers\office workers that will check from time to time some of the restaurants, food stores and places like soap work shop too. So here you would risk having a trouble and pay some serious fine. I must find out which office need to see, or accept my SA, and then I can find out if I could also go for Scotts one!
Yill, maybe is not a bad idea to call such offices to make sure you will not get in trouble what may’d be not worth it. I understand that is a lot of work, and calling, and emailing and so on – but I think is better to be on the safe site. I will open new thread I think or just continue to post info here, to show step by step how it went with me. So maybe it will be something for other to get idea how things work here.


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## The Efficacious Gentleman

I agree, it's better not to risk it.  I was toying with the idea of selling my soaps as "decoration only" and therefore avoiding the whole issue but I think I'll give the proper route a good go first of all.

On a further note on getting checked, YOU are the responsable person, so they will be looking to YOU to get at all times.  Not a nice thought if you're thinking of playing games with it.

Twiggy - Do you have to pay at some point for the work that they have done?


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## Twiggy

The Efficacious Gentleman said:


> Twiggy - Do you have to pay at some point for the work that they have done?



Until now nothing – and a lot of work is already done, I had a lot of food ingredients and each I had already check with them if I will be ok to use plus some oils have SDS (Safety Data Sheets) checked – so all my ingredients are approved to be ok to use I wanted to avoid the situation when I send them all data prepared, with my super-duper recipes and they telling me that half of the stuff is not allowed  It was a lot of emails and they could easily send me a bill for that – but they didn’t


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## Saponista

I'm wondering where you found the regulation about molecular weights @efficacious gentleman I haven't seen anything about that myself and any of the handmade soap I have looked at doesn't have that on the label, is it something to do with the EU portal submissions? Molarity is really easy to work out, I do it all the time at work. Most solution recipes give you the ingredients in molarity. You'll find all the info you need on an a-level chem website. If you reach a point where you need help just give me a shout. 

 I have been looking a bit more deeply into cosmetics assessments, the company which seems to be most widely used in the UK quoted me £179 for one simple anhydrous base recipe with 6 variations to that recipe eg scent and colour. Each variation can have a max of 5 different ingredients. The company basically said that along with that price they would help with sorting everything to get my business sorted and legal.

 There is another option as many of the soap supply companies offer 'off the shelf' assessments. One company offers an assessment from the same company above which includes 8 variations rather than 6 for only £165 but you are basically on your own with regards to complying with the rest of the regulations and to a certain extent you are required to use their ingredients in your products which would make keeping costs down difficult. 

 There is some interesting info on this page though 

http://www.bathbomb.biz/acatalog/Cosmetic_Safety_Assessment_Packages.html

 There is a list of common approved ingredients and accepted % usages so it might be worthwhile checking if your recipes fit within those parameters before going to get them assessed.

 I'm still no further on with working out how to calculate best before dates for my soaps and the regulatory company were really cagey about giving me help with that before I handed over any money to them.


----------



## The Efficacious Gentleman

The molecular info was more based on using nanites or some such (don't the Borg use nanites?  Freaky) but for normal soaps and things it doesn't seem to be needed.  Which is a good thing!

As for the asessments, I thought that each ingredient had to be approved and that you could use that as you wanted - so if you had 10 oils and 10 colours approved, you could make mixes using these in combination?  I am still working towards getting good information on what I would need to do about my process/location for soap making before I worry too much about recipes, though.

The first option sounds best if you can use your preferred ingredients.  The second option sounds like a supplier tying you in to an agreement!  Also look at how much they charge for single ingredients, in case you want to change from one CO to another, for example.


----------



## Saponista

I think getting each ingredient approved and using them in any combination worked previously but the new regs that came in in 2013 seem to have put a stop to that as far as i can tell. The new thing seems to be that you have to have each recipe assessed and accepted which sucks as it means that creativity is stifled. Especially for small craft businesses.


----------



## Saponista

Oh and I think the nanites might have something to do with nanoparticles. Loads of cosmetic glitters and oxides now have to be labelled as nanoparticles if they are a certain size. There seem to be environmental issues with them bioaccumulating in things like shellfish.


----------



## The Efficacious Gentleman

Wow, that is very pants!  Makes sense in some ways - you can't just use any amounts of lye, for example!  But not so great in other ways.

If that is the case, the costs should be some what lower, I think.  I hope!


----------



## Saponista

I still can't believe your €600 fee just for some info!


----------



## The Efficacious Gentleman

Indeed!  It's madness to expect me to pay just to find out what will be expected in the process.

I have found the name of another company, will see how helpful they can be.  Sending them an email this evening about it and hope that I can get the full information and then decide if it's an option for me or not.


----------



## Saponista

I hope you get all the info you need  are you considering soap selling as your only income or are you still planning to work at whatever it is you do at the moment?


----------



## The Efficacious Gentleman

What I do at the moment seems to be sitting in the office looking at SMF  

But to start with, it will be supplimenting.  Once I know that it is possible, I'll get my recipes sorted and go to local chemists shops - they are independant here and can decide what they sell at a local level.  I'll see what they are interested in and go from there.  An initial order that goes some way to offsetting the start up costs would make it a better option. 

Of course, once the recipe and all that is signed off, the reg costs are over and then I can make 100 batches and do the PIPs myself so there are no more costs involved unless I want to change a recipe.

I would like to have it be the main income, though.


----------



## Saponista

I am also sat at work on SMF lol! Dreaming of the day I can break the ties and work for myself. I dropped down to 4 days a week so I now have Fridays off to experiment but I still need cash to buy stuff to experiment with.


----------



## Saponista

You could try crowd sourcing to get some money to start up.


----------



## The Efficacious Gentleman

To clarify on the other post - I'll take some samples to market and see what people like and don't like, beyond my testing friends and family.  No point getting a recipe signed off if no one actually wants to buy it!


----------



## Saponista

That's the difficulty isn't it because you can't give it away to anyone other than friends and family without a safety cert. which makes market research nigh on impossible.


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## The Efficacious Gentleman

As I read it, I can't sell soap to the general public.  Giving a gift to a chemist to see if they want to stock it is another thing............................


----------



## Saponista

I guess that still falls under the friends and family thing, as you aren't actually selling it to them.


----------



## Lindy

My understanding of your SA is that you will have a list of oils and additives with the maximum allowed percentages so you can play with your recipes.  If you need more additives then there is a charge for each one added to your SA. I hope that helps you out...


----------



## The Efficacious Gentleman

Thanks, Lindy.

The recipe side of things is not too bad, but the actual production process requirements that could be the problem - Do I need to use an extra "kitchen" with hot running water or is my normal kitchen okay or do I need another room but with cold water.....................until that is answered I won't know if it is a viable plan or not


----------



## Yill

I have received an example of a PIF which also contains GMP. I still find it quite hard to understand how that translates into the way you should set up your soaping kitchen in order to comply to the rules. ISO 22716 is al about GMP, but I still have to read it, it's loooong lol. I wish there was just a simple document that would explain what you need to do to get the production process in order. Like: Have a separte kitchen, use only stainless steel utensils, use only laboratory glass pitchers, keep your oils in a cool dark place, keep your EO's stored in a dark cabinet etc. etc.

 I completely understand Gentleman's process I'm following the same route!


----------



## The Efficacious Gentleman

Welcome to the world of pain 

The biggest issue is that there is an EU legislation with the MINIMUM requirements - each member state can add on to it anything that they fancy.  That's why we have the example of the UK being allowed to use the usual kitchen but in Germany the goverment added the requirement of a different room.

Hopefully the company I emailed last night can shed some light on things.  Failing that, there is a kind of Trading Standards body here in Austria that I can try - knocking off the options as I go, but also find more options that are potentially more helpful!


----------



## Saponista

The worst is that I seem to get a different answer from each different person I contact.


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## The Efficacious Gentleman

Some progress!  Good news for the Germany-dwelling members here - 

"Sie sollten direkt bei den Behörden anfragen. In Deutschland wird es akzeptiert, dass in der Küche gesiedet werden darf. Ob dies in Österreich auch der Fall ist, kann ich leider nicht sagen. Fragen Sie beim Bundesministerium für Gesundheit in Wien."

I received this from a company I emailed last night (top marks for response time!) who are able to work with me in Austria but seem to struggle on the finer points of where I can or can't make soap to sell.

But what the above states is that it IS acceptable to use the same kitchen!  I'm sending an email off to the health ministry here is Austria to get the 401, as you Yanks would say.


----------



## Lindy

Gentleman that is so fantastic!!!  You have worked hard to get this information and you stuck with it.  Yay!


----------



## The Efficacious Gentleman

Thanks, Lindy!

A little bit annoying that there are mixed messages - some places saying you cannot use your kitchen in Germany, others saying you can.  Just hope it is the case that I can in Austria.  Then my plan is - 

Keep working on recipes
When I have some recipes that I really like, contact local independant Chemist shops (Apotheken) in my area and see which ones they would be interested in buying
Get the recipes that the Apotheken want signed off by the EU

That way I am not wasting money getting a recipe signed off if no one is interested in using it.

I wonder what the legal isssues would be of sending a sample of soap that is non-registered to customers when they purchase something else so that they can test it and give feedback?  Although in fairness I think often from a customer point of view, it's more about additives, water replacement and scents, once you have a base recipe that is not drying, bubbles well and so on.


----------



## Saponista

I think there might be some difficulties legally as if anything happened to those people using the soap, allergic reaction etc. then you wouldn't have any legal cover. I think you could probably have some samples open on the counter for people to pick up and smell and tell you which scents they would be interested in buying though.


----------



## The Efficacious Gentleman

I've just seen that http://www.cosmeticsafetyassessment.com/ are toying with a very interesting idea - selling completed recipes already signed off!  If you don't want to develop your own, or they have something that you don't have in your roster, you can just buy the pre-approved recipe, make it and sell it!  Should save a few euros if it is a similar recipe or something totally new that you want to sell but don't want to pay for a custom recipe to be approved.


----------



## Saponista

Where did you see that? Might be a good idea for water based things like creams and lotions that have to be micro tested.


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## The Efficacious Gentleman

It was posted on their facebook page


----------



## Lindy

Scott has been doing that for a while with lotions and creams, however, there are some specifications with the type of container you use.  They need to be the airless bottles to help with preservation of the lotion otherwise they have to be challenge tested.


----------



## Saponista

Are they ones with a pump top or something then?


----------



## Lindy

They are a pump top but they do have any air in them and as they are use up there is a bottom that comes up in the bottle.  There are also airless jars too, although they are expensive.

http://www.newdirectionsaromatics.ca/airless-dispenser-refillable-clear-bottle-with-cap-p-2319.html


----------



## The Efficacious Gentleman

Another update - I have my CPNP access granted!  A little bit ahead of time, I know, but it's then aslo something that I can learn before I actually need to use it.

I had some information through from the health ministry here in Austria but it is not overly clear.  So I emailed back to the assesor to say that I would do the PIFs/PIPs myself as well as the regular labelling.  But I would like to use them for the initial label planning and my recipe sign off (seems to be reasonable costs, will post examples when I am back on my computer) but I also asked if I needed anything else, such as an assessment of my method and location - if I do, then I'll see if they can do this and, if so, what are the requirements.

Of course, in the mean time I'm working on the most important thing - making soap!  Even if I can't get to a point of selling it, I'm going to have some kick donkey soaps.


----------



## Lindy

Good for you!


----------



## Miz Jenny

E.G. that's great news! Your donkey soaps will be amazing.


----------



## Yill

That great!


----------



## Twiggy

How on Earth I miss so much updates on that VERY IMPRTAND thread?!?!?!?! 

E.G. Wow, you r way ahead of me lol I would love to know which assessor you r in contact with, and what’s the costs, maybe you could PM me about it? I contacted Scott company and when I will have green light from authorities here I’m planning to use them. 

So I contacted my Veterinary and Food Safety Office in my region, but I didn’t reach the men responsible. So I’ll try on Monday again. 

Also the news on ONE kitchen… I caress my mind with that possibility, but not having much hope that I will be able to use such a chance to create soaps in my own daily used kitchen.

Guys pls tell me what is PIP (some more stuff to take care of) and GMP?

E.G. I really don’t want to put you down, but is better to check such information. I’ve found on german forum such info:
“Für die Österreicher kommt nochmal erschwerend hinzu, dass man bereits eine artverwandte Ausbildung hinter sich haben sollte - z. B. im Laborbereich. Alle anderen müssen eine Zusatzausbildung absolvieren, die nochmal zusätzlichen Zeit- und Geldaufwand erfordert.”

Plus here even you build the extra kitchen, buy extra stuff for it, make it stick to the rules, veterinary office will love it, you must go to some kind of building department and ask them kindly to change your kitchen “usage purpose”, is like to get the allowance to use one of you home rooms to run business there… I think I’ll go crazy – sometimes I think that the goal for government here….



 

 

 :crazy:



The Efficacious Gentleman said:


> Another update - I have my CPNP access granted! A little bit ahead of time, I know, but it's then aslo something that I can learn before I actually need to use it.
> 
> I had some information through from the health ministry here in Austria but it is not overly clear. So I emailed back to the assesor to say that I would do the PIFs/PIPs myself as well as the regular labelling. But I would like to use them for the initial label planning and my recipe sign off (seems to be reasonable costs, will post examples when I am back on my computer) but I also asked if I needed anything else, such as an assessment of my method and location - if I do, then I'll see if they can do this and, if so, what are the requirements.
> 
> Of course, in the mean time I'm working on the most important thing - making soap! Even if I can't get to a point of selling it, I'm going to have some kick donkey soaps.



I did exactly the same! I used Scots tips and guides… But I have question, do you get any feedback, that is approved or something, or you just enter your recipe and id than?


----------



## The Efficacious Gentleman

Hmmm, it seems that a lot of the places where we get our advice from seem to have a different idea from the next one!  Some assessors say one thing and then a second says something else.  It might just be interpretation of the regulations.  Hopefully it is just that!

I'll PM you the assessor that I found.

PIP is a Product Information Pack (in PIF, the Pack becomes File) and is just an online record of each batch of soap.  Let's say that you get 5 recipes approved, every time you make a batch of any one of these recipes to sell you would need to create a PIP/PIF online - the unique number generated is then your batch number for going on the labels, so that each soap can be traced back to the PIP stored online.


----------



## Twiggy

I think first think we should do is to contact an officer from Amt für Gesundheit und Lebensmittelsicherheit in our area to find out what they would like to in our kitchens, our papers. Assessor know nothing about it, as they will not perform possible controls for us. So for now I contacted one, but we think that he is not the one, who is responsible for my area – he doesn’t know sure himself. So we search.

About the PIF and PIP, I know about to keep records in PIF, is PIP obligatory, or I can stay with traditional paper version which I think PIF is. Is PIP generated in some kind of application, or webpage? 
I know the bachnumber you can create yourself.

Thank you for PM.


----------



## The Efficacious Gentleman

You have to register each batch on the CPNP website (http://ec.europa.eu/consumers/sectors/cosmetics/cpnp/index_en.htm - you can select the best language for you there) and use their batch number.  As far as I am aware, this is a requirement rather than just filling in a paper version.


----------



## Twiggy

The Efficacious Gentleman said:


> You have to register each batch on the CPNP website (http://ec.europa.eu/consumers/sectors/cosmetics/cpnp/index_en.htm - you can select the best language for you there) and use their batch number.  As far as I am aware, this is a requirement rather than just filling in a paper version.



I’ve read those documents last year and find nothing about each batch. I’ve back then registered and entered my soaps recipes. Ok, looks like I’ll reading it again, maybe something has changed (???) Or I’ve maybe overlooked it somehow…


----------



## Twiggy

Ok, so today I’ve succeed to reach my responsible person, and I finally know his requirements for soaping kitchen.


----------



## The Efficacious Gentleman

Twiggy said:


> Ok, so today I’ve succeed to reach my responsible person, and I finally know his requirements for soaping kitchen.


 
Is that in DE?  From the gesundheits Amt?


----------



## Twiggy

Yes, it can be Landesamt für Gesundheit und Lebensmittelsicherheit or like in my case it is Ordnugsamt department Lebensmittelüberwachung. The thing is, in each city that institution has little bit different name, here where I live we had 3 or 4 such offices and it took us a while to find the one responsible for my area. It has to do with “food” here, some sort of Lebensmittelamt.

Did you contacted yours yet?


----------



## The Efficacious Gentleman

Not yet - I need to have a word with a few people (there are a few local sellers it seems) to see who I would need to contact.  Gah, so much admin - really makes one work for it!  Still, it means that not so many people go through all the hoops to sell soap so it isn't such a saturated market.


----------



## Twiggy

That is a good idea to do. But if they are so protective about any information like here in DE… That so odd I have to tell. Well I may understand why, as it is so much work to achieve, but on the other hand even with full info in hand not all people will decide to go through that process. 

The best idea, if I could give any advises, is to call any Lebensmittelamt in area, and just ask if they are the one to contact. They will lead you further to your responsible person. I already can start with my kitchen redecoration, my SA is nearly done, I still need to contact Bauamt to ask if we need to change officially the purpose of using our cellar kitchen as working place, and Gemaideamt - our community authority to ask them if they don’t mind my having business set in my house…


----------



## The Efficacious Gentleman

Twiggy said:


> That is a good idea to do. But if they are so protective about any information like here in DE… That so odd I have to tell. Well I may understand why, as it is so much work to achieve, but on the other hand even with full info in hand not all people will decide to go through that process.
> 
> The best idea, if I could give any advises, is to call any Lebensmittelamt in area, and just ask if they are the one to contact. They will lead you further to your responsible person. I already can start with my kitchen redecoration, my SA is nearly done, I still need to contact Bauamt to ask if we need to change officially the purpose of using our cellar kitchen as working place, and Gemaideamt - our community authority to ask them if they don’t mind my having business set in my house…


 
Did you have to do much to your kitchen?


----------



## Twiggy

My cellar is very old, and ugly… So I basically must do everything there, but also there is some guideline – I will try to find the link for you. What such kitchen must have:
- walls covered completely with easy clean tiles 
- 2 washing sinks unites – one to wash hands only, one for soaping purposes
- toilet LOL – but then we said that is in our house, so lucky we can use our toilet  
- washing machine can stay in my soaping kitchen (yuppi!!!)
- all devises and furniture has to be easy to keep clean/sterile 
- I also find out that I can get SA from UK, in worst case I will have to get it translated…
The fact the washing machine can stay, and the UK SA will be good – was 2 major facts for me. As if the washing machine would be not allowed in such room, then I would need to change my whole project! And of course with English SA I’m saving not small money  Plus I was already half way done with them…

EDIT: Ok, I’ve found it!
http://www.ikw.org/fileadmin/content/downloads/Schönheitspflege/SP_Kosmetik-GMP2010.pdf
 That should help you to check if you ready to sell, there should be also section where kitchen standards are mentioned – but to be completely honest I didn’t went through it yet…
E.G. have a look on www.ikw.org – you should have such think in Austria too. There is PLANTY to read! I’m glad I was reading since some time here and there, otherwise I would sit and cry if I had to catch up will all this right now :\


----------



## The Efficacious Gentleman

Thanks for the links, Twiggy.  I need to improve my German reading a little bit 

But having read the HSE (UK) Guidelines and some text on the UK SA site, it appears that there in the UK it is okay to use the normal kitchen with some things to watch out for.  My argument would be that if someone in the UK can make soap in this way and it meets the EU requirements, then soap made in Austria or Germany also meets the requirements if made in this way.  

Tiles are not as easy to clean as a solid covered wall - my kitchen area has a smooth finish that is easier to wipe clean than the grout between tiles.

Was it stated that you could not use your kitchen?


----------



## Twiggy

I guess you could try to rise that argument while speaking to you officer- it would be interesting to hear what he/she would reply. I was worried that I will not be able to make it at home at all, and if, then my washing machine will be on the way. So that was my first question, if I can produce my soaps at home, and the answer I got was “Yes, but you need to have separate work room, covered completely with tiles – that is very important. Washing machine is not perfect, but it could stay if you will not make soaps and laundry at the same time. Also laundry detergent must be separated from the soap part and be stored in separate cupboard, or separate room”. O well for me is fair enough, I have room, was going to redecorate it anyway and make there my soaping corner. Now I will just make it little bit higher standards than I was planning at the beginning. 

About the translation, I’m using feature/app included in google chrome, it does pretty good job with simple translation, I know not all can be translated, like open in chrom PDF files, but most of the time when I’m too tired reading in German I just let my chrom translated for English – is good enough to understand


----------



## The Efficacious Gentleman

I use Chrome on my other laptop, so will have a look later.  Again, looking through the pdf nothing jumped out that says it cannot be the usual kitchen in theory.


----------



## Twiggy

The Efficacious Gentleman said:


> I use Chrome on my other laptop, so will have a look later.  Again, looking through the pdf nothing jumped out that says it cannot be the usual kitchen in theory.



I think is different from one county to another, but also from one office to another within one country or even region… You really should find responsible officer and ask him all that questions, as I’m afraid that we can read tons of stuff, but is that one men who will tell you how it really work for him in his area – he  or she will come to check you working place and you documents, so it should be made due to his/hers suggestions. I know is not fair, but it is how it is :\ We are dependent to office workers :\


----------



## Dorymae

OMG!  I'd be grabbing a glass of port and calling an attorney familiar with the regulations.  If they get that detailed I'd be afraid of leaving something out!


----------



## The Efficacious Gentleman

In some ways it's simple - recipes need to be checked, processes & location need to be okay, paperwork needs to be filed.  The issue comes with what the second point actually entails and it seems that each inspector has some leeway with what they think.  Certainly more complicated than in the US!


----------



## Dorymae

Much luck to you!  Kudo's to you for taking the time to understand as much of it as possible.  I'm sure you'll be very successful in your venture.


----------



## The Efficacious Gentleman

I hope so, too.  In some ways it's great, as it keeps the competition to a minimum.  Just bear in mind, when a country looks to have a free trade agreement with Europe, the most stringent requirement is usually the one that has to be adopted....................


----------



## Lindy

I'm waiting to see if Canada changes to the EU form as we have, or are working on having, a free trade agreement with Europe.


----------



## coffeetime

Noooo! Say it isn't so, Lindy! It took me forever to register my recipes and make sure my labelling was compliant. If I have to have my house inspected too, I just won't make soap anymore.


----------



## Saponista

Have you got a link to the HSE guidelines please eff?


----------



## The Efficacious Gentleman

https://www.gov.uk/government/uploa...ment_data/file/39334/10-761-guide-to-cpsr.pdf - not the HSE doc, but an interesting read regardless.

Ahem......it appears that I was reading the guidelines for Asia on a HSA site, not the HSE................... :roll:


----------



## Saponista

I do wish there was some centralised European site that laid out everything that was useful in one place. Thanks eff, I will have a gander.


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## Lindy

coffeetime said:


> Noooo! Say it isn't so, Lindy! It took me forever to register my recipes and make sure my labelling was compliant. If I have to have my house inspected too, I just won't make soap anymore.


 
 Hard to say what HC will do.  I'm hoping they leave us alone.  I love the new portal for registering our recipes but I don't want to have to have my home inspected.... :shock:


----------



## The Efficacious Gentleman

Time for an update - 

So it seems that in my area there is no issue making things at home in the kitchen per se - as long as I can meet the "Good manufacturing process" and it causes no issues to the neighbours then it is fine.

What might well be an issue is that there appears to be some sort of educational/experienced based requirement that I would need to fulfil to be able to make cosmetics for selling.  I'll be running it through with The Admirable Lady this evening to untangle the mix of German and Legalise.  I also have the contact information for the office there, so I can arrange an appointment and go and speak with them directly on the subject.  Maybe take some bars of soap and do a zap test in front of them as proof that I know what I am doing  Again, this is annoying as it is not really an EU requirement, just a local thing.  Which is why I think an appointment together would be a good idea.

Oh well, a little step forward and then there is


----------



## Twiggy

The Efficacious Gentleman said:


> Time for an update -
> 
> So it seems that in my area there is no issue making things at home in the kitchen per se - as long as I can meet the "Good manufacturing process" and it causes no issues to the neighbours then it is fine.
> 
> What might well be an issue is that there appears to be some sort of educational/experienced based requirement that I would need to fulfil to be able to make cosmetics for selling.  I'll be running it through with The Admirable Lady this evening to untangle the mix of German and Legalise.  I also have the contact information for the office there, so I can arrange an appointment and go and speak with them directly on the subject.  Maybe take some bars of soap and do a zap test in front of them as proof that I know what I am doing  Again, this is annoying as it is not really an EU requirement, just a local thing.  Which is why I think an appointment together would be a good idea.
> 
> Oh well, a little step forward and then there is


It makes me so jealous that you will not need to build extra kitchen – but in the same time I’m so happy for you! It must be big relief! How about the other issue, the educational bit – did that meeting took place already? To be completely honest I would join such a course or whatever they require- just to get that extra knowledge for myself.

My update is poor, but in the same time is a big step forward – the cellar redecoration is in progress!!!!


----------



## The Efficacious Gentleman

Latest update - 

I only need to meet these educational/experience requirements if I want to register a company.  One of the requirement options is that I run a business for 6 years, which of course I couldn't do if I needed to register the company, as I wouldn't have the 6 years................. you get locked in this circle.  So I can run it as a sole-trader, no company reg number and so on.

Just working on getting the insurance sorted now.

As for the kitchen, I still have to meet the best practice guidelines, but those are actually quite straight forward, but I will have to soap with the windows closed........................


----------



## Twiggy

I think I didn’t understand - running company and being self-employed (sole-trader) is not the same? I thought that if you self-employed you r running one person company…


----------



## The Efficacious Gentleman

Twiggy said:


> I think I didn’t understand - running company and being self-employed (sole-trader) is not the same? I thought that if you self-employed you r running one person company…




To all intents and purposes, yes. But with no company registration number and so on. 

A sole trader is technically a company, but not classed as a company.


----------



## Twiggy

Ok, thank you for the explanation EG


----------



## The Efficacious Gentleman

No worries - when I wrote it I was trying to make clear something that is not overly clear in the first place  Makes it interesting.

But seriously, something needs to be done with all of this regulation being applied differently by different member states.


----------



## The Efficacious Gentleman

Another update for this saga, this epic adventure. I am frodo bearing this ring! It's starting to get to me, as you can tell.........

So I went to see someone from the local government regarding all of this company registration and it turns out that I do need to have a company registered. As I don't have the required qualifications, there are two options:

1 - they are looking at whether or not they can put together a test of sorts which shows whether or not someone can make cosmetics (soap is classed as a cosmetic under eu law) even though they don't have a degree in chemistry. 

2 - if the test is not possible, I can get someone who does have the qualification to be the name on the registration and then I actually do the work. Then after 6 years I can be the name on the registration

All fun and games. While waiting on that I'm trying to get an idea of insurance costs. If it is too high then the whole thing is a write-off so it's an important piece of information. 

The saga continues.........


----------



## welsh black

No wonder there are very few soap makers in the EU, I think I'll make candles!! No hassle and better mark up.


----------



## The Efficacious Gentleman

I was the second person in that office that week about soaping, hence their thoughts on a test.  I can understand the principle of needing to make sure people can actually safely make cosmetics but it is a bit extreme.  Will wait and see what comes.

I was poised to buy a load of wooden bowls with lids from China for shaving soaps - had the production and shipping all sorted out - but it's on hold until I can confirm that I can sell


----------



## The Efficacious Gentleman

Okay, so more progreess:

There IS a course that I can do that would satisfy the authorities here, it's not overly expensive all told.  But then I also have to do a course in how to run a business as a self-employed person.  That one is a bit more expensive, but between them I'm looking at 900€ so not too bad.  Plus, a business course is never a bad idea especially as I am not overly well versed in how things work here in Austria from that point of view.

The remaining hurdle is insurance.....................

.............oh, and getting people to buy my soaps, must not forget that part.


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## Twiggy

Well done, so it looks like we both getting there  My cellar is still not finished but soon! The heater nad running hot water are connected finally!  I’ve contacted my responsible officer from Food and Health department and he had said that he is not interested in all that stuff what has to do with safety assessment, he will newer look in to my papers, so for him I don’t have to run that paper work :crazy: ( yyyy what … ???) OK, I’ll run it any way, just to be on the safe site. What he will do though is, he will come and take the samples of my soap and run some tests on them – then he will truly know what’s in them… Sorry but for me, that wild interpretation of EU law across the Europe is just hilarious! 

The open parts are Bauamt - apparently the most difficult here, and insurance. In DE insurance like we need is round 200 E – it is what I’ve heard


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## The Efficacious Gentleman

Wow, that is crazy news, but also great that you are also getting there and sorted.  It's frightening to think that we can both sell in AT and DE even though both countries have such differing rules................



Twiggy said:


> ................. In DE insurance like we need is round 200 E – it is what I’ve heard


 
Is that per year?


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## Twiggy

The Efficacious Gentleman said:


> Is that per year?



Yep, it’s per annual 

It is nice, to know things r going further, but sadly I'm quite sure I will not be able sell for this year Christmas :sad:


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## Twiggy

Ah, Craig, I’m not sure if u know, but better ask if u need a special scale, here they call it geeichte Waage. Is a special scale it can by use to sell things legal – calibrated and approved by one of your authorities. Is another expensive buy, the cheapest one cost here round 200E, and you can only use it if you products are not lighter than 50 grams. If they are, you need scale for around 400E. That all is so crazy, and so a lot of it, that it make my head spin when I’m trying to thong about it… And seriously – sometimes I just think that kind of rules are made just to scare small manufacturer off…

That is the link to german forum thread if u would like to read more about it :
http://www.seifentreff.de/gewerbliches-seifensieden/geeichte-waage-t12902.html?hilit=waage


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## The Efficacious Gentleman

They haven't said anything on that side of things................yet!


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## Twiggy

I’m not sure, but those are the things we should somehow know our self… Look through that forum is a lot of information for Austria as well there. God knows what I still don’t know and is required in DE :Kitten Love:


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## The Efficacious Gentleman

Well, I have a LOT of links sent through to me from the WKO.  I need to learn it all and then go for a chat with them - if they are satisified that I know my stuff, they'll write a letter to the chap who does the company registrations to tell him so, then he can give me my certificate (it is ALL certificates here) and then I can crack on.  If there is something in there about measuring devices then so be it.  If not, then for us in this corner (every county is different here!) it might well be okay.


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