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:

 

[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.

 

[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.

 

[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.

 

[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.

 

[MirandaH]

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:

 

[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

 

[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

 

[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

 

[Twiggy]

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!

 

[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?

 

[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.

 

[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!

 

[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

 

[Yill]

@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!

 

[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.

 

[Lindy]

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

 

[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.

 

[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.

 

[Twiggy]

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

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

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!!