Entering the murky world of EU regulations

[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!

 

[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?

 

[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

 

[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.

 

[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.

 

[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.....

 

[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

 

[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.

 

[Twiggy]

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!

 

[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.

 

[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

 

[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

 

[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.

 

[Twiggy]

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...

 

[The Efficacious Gentleman]

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.

 

[Twiggy]

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

 

[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:

 

[Twiggy]

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.

 

[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?

 

[Twiggy]

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