Do I Have To Put My Home Address On Labels? (United Kingdom)

[rpclarke]

Hi,

I make my own cosmetic products from home and I'm working on the labelling. I'm based in the United Kingdom.

My question is, do I have to use my home address on the label? According to the government website on labelling requirements, it says the following:

"A Responsible Person must have a UK established address to make cosmetic products available in GB. A UK established address does not include mail forwarding or PO box addresses."

This implies I must use my home address on the label, and I can't use a virtual office instead. Is this correct? Obviously I don't really want to include my home address on the products. It won't look very professional being a residential address and I don't really feel comfortable having my personal address available like that. I've been looking at virtual addresses where I can get any mail (not that I expect much) forwarded, but the government website seems to say I can't use this. I just wondered if someone has some advice, can I use a different address?

Thanks.

 

[TheGecko]

If the UK is like the US, you MUST use the address that the product is made at. Now in the US I can get away with not putting my street address on the label (just City, State and Zip Code), but only because my address is publicly available via the Secretary of State's office and on my website.

I understand your concerns, but the odds of someone coming to your home over a product...you'd have a better chance of winning the Lottery.

 

[rpclarke]

I can't seem to find any information to say I don't have to include the full address.

I know it's unlikely anyone would come round but it still makes me feel a bit uncomfortable. Plus I live on an avenue which is very clearly a residential address so I don't think it looks great. I just feel like there must be a workaround as there are plenty of people who run a business from home.

 

[AliOop]

Have you contacted any of the assessors for the required recipe assessment? I would think they might know the answer to this.

 

[TheGecko]

I can't seem to find any information to say I don't have to include the full address.

I know it's unlikely anyone would come round but it still makes me feel a bit uncomfortable. Plus I live on an avenue which is very clearly a residential address so I don't think it looks great. I just feel like there must be a workaround as there are plenty of people who run a business from home.

I checked several different places

• The name and address of the responsible person is required on both the container and the outer packaging. If a product is made outside of the UK, the country of origin must also be given.
• The UK responsible person can be: the UK-based manufacturer, or a person designated by a written mandate by a manufacturer that is outside the UK, or a distributor, or the importer. This is a very simplified look at this new UK rule.

From Making cosmetic products available to consumers in Great Britain:

Labelling cosmetic products
The labelling for cosmetic products must be easy to read. The container and any packaging must be labelled with:

• the name and address of the Responsible Person
• the country of origin if the product is imported to the UK
• the weight or volume
• the date which the cosmetic product can be used until
• any precautions for use
• an identification number (for example batch number)
• what the cosmetic product does
• the ingredients - these can be provided solely on the packaging. Note that nanomaterial ingredients must be followed by ‘(nano)’

In some cases, the usage date and the weight or volume may not be required, for example where the contents are less than 5 grams or 5 millilitres. This may apply to free samples and single-application packs.

It may not be practical to include precautions and ingredients for certain cosmetic products, for example due to available space on packaging. If this is the case it is important to include this information within the packaging, for example on a leaflet. A symbol should be used to indicate where this information is.

There are no work-arounds in this instance and quite frankly, there shouldn't be. Put the shoe on the other foot...you purchase an artisan product that harms you. You look to the label...there is no address or the address leads you to private mail box in a strip mall. What if the harm is enough to scar you or disable you? Now what do you do?

I'm 60+...I don't think I have ever checked a product for the address unless it was to see if the item was made in China. In all the businesses I have run out of my home, I've never had anyone look at my address and say, "Well your service/product must suck if you don't have a commercial address."

 

[rpclarke]

Have you contacted any of the assessors for the required recipe assessment? I would think they might know the answer to this.

Thanks for the advice, I have contacted an assessor and they confirmed that I do have to use my full home address on the labels unfortunately.

 

[The Efficacious Gentleman]

If you made them somewhere that wasn't your house, you would have to use that address instead of your home address. Of course, the EU cosmetic regulations (which stayed in place after Brexit) are built for actual companies but still include cottage industries. Bloody shame, I say

 

[TheGecko]

Of course, the EU cosmetic regulations (which stayed in place after Brexit) are built for actual companies but still include cottage industries. Bloody shame, I say

So a 'cottage industry' isn't a business? That you're okay with purchasing products from someone who isn't required to adhere to the same standards of cleanliness, safety and other good manufacturing practices? I guess since I make soap in my kitchen instead of a factory, I shouldn't have to sanitize my equipment or wash my hands or even put my hair back. That's it's okay if I fudge the weight of my products? That I don't follow safe usage guidelines or list all my ingredients? That I'm using rancid oils? Or that I have some contagious illness and just coughed and/sneezed all over the face cream I just potted. Because, you know, I'm not a 'actual company'

 

[The Efficacious Gentleman]

Not quite what I meant - I think it's very important that standards are followed, which is why I actually prefer the EU version over the US where it's more of a free-for-all. But without ANY distinction between a small business and a massive commercial entity is a touch too far. For example, in Germany you can't even use your usual kitchen at all, no matter what GMP you follow. It has to be totally separate.

I just feel that the EU as a whole and the individual counties could do more to support small soapers

 

[TheGecko]

Not quite what I meant - I think it's very important that standards are followed, which is why I actually prefer the EU version over the US where it's more of a free-for-all. But without ANY distinction between a small business and a massive commercial entity is a touch too far. For example, in Germany you can't even use your usual kitchen at all, no matter what GMP you follow. It has to be totally separate.

I just feel that the EU as a whole and the individual counties could do more to support small soapers

And it's understandable, because let's be honest...folks will take advantage.

I personally would like to see some kind of regulation in the US when it comes to bath and body. While soap making is definitely a free-for-all for the most part, the cosmetic industry isn't really any better since it is voluntary. It's only when you make drug claims that there is any real regulation.

It's the assessment crap that I totally disagree with. I'm all for making sure that your base recipe meets all safety guidelines, but you should haven't to pay out the butt every time you want to use a different colorant or scent.

 

[The Efficacious Gentleman]

It is a fine line between helping the little folks but stopping them from abusing the system