For UK/EU soap makers. CPNP portal help

[Deadgroovy]

I'm looking to get ready to start selling my soaps and I'm in the process of registering my products (I'm only making CP soap) with the EU Cosmetic Products Notification Portal. As with all government departments, it's a bit of a minefield!
Has anyone on here completed it?
My main question (up to now) is do I have to register all of my soaps separately?
I have Stuart Graingers powerpoint guide, but it doesn't explain this clearly.
Any help welcome

 

[The Efficacious Gentleman]

I've not looked recently, but as memory serves -

You need to register yourself first of all, then get all of your product assessments sorted out, as you'll need those numbers for the portal.

You have to register each batch, and each batch will have a batch number which needs to be on the label of that batch.

Other than that, I don't recall the portal being all that tricky. Worst part is any local requirements that there are (approved scale in the UK, soaping area separate from your kitchen in Germany, things like that)

 

[Deadgroovy]

I've not looked recently, but as memory serves -

You need to register yourself first of all, then get all of your product assessments sorted out, as you'll need those numbers for the portal.

You have to register each batch, and each batch will have a batch number which needs to be on the label of that batch.

Other than that, I don't recall the portal being all that tricky. Worst part is any local requirements that there are (approved scale in the UK, soaping area separate from your kitchen in Germany, things like that)

Great, thanks! Have just sent off my recipes to be assessed, will be 3-4 weeks before i get results. I have registered with the portal. Is it a one time process? Do I need to do this for every batch I make?

 

[The Efficacious Gentleman]

Registering yourself as a responsible person is a one time thing. I think that you register a recipe one time, but every batch of that recipe has to have an entry on the portal.

That is the whole purpose of the portal - someone uses a product of yours and there is an issue. The batch number can be linked to a particular batch that you made, which can be linked to a particular batch of ingredients that you used, and if there is a bad ingredient you can also see which other batches that was used in and order a recall if needs be

 

[Deadgroovy]

Registering yourself as a responsible person is a one time thing. I think that you register a recipe one time, but every batch of that recipe has to have an entry on the portal.

That is the whole purpose of the portal - someone uses a product of yours and there is an issue. The batch number can be linked to a particular batch that you made, which can be linked to a particular batch of ingredients that you used, and if there is a bad ingredient you can also see which other batches that was used in and order a recall if needs be

Again thanks! That explanation makes it a lot clearer. I wonder if everyone selling soap on Ebay, Etsy etc in the UK do this

 

[LilyJo]

No they dont and they are breaking the law!

Its one of my pet hates and something that has a huge affect on UK/EU soapmakers - there are so many YT or IG posts with recipes and encouragement for people to just go ahead and sell that people think you can just do that. It might be legal in the US or elsewhere but not getting products safety assessed is against the law here, will invalidate your insurance, can prompt seizure and prosecution from TS.

I am with TEG, the portal is pretty simple and once you have your recipes back its straight forward to fill in and upload. Dont forget you will need images of your packaging and will need to update the portal should that change. If you make an amendment to the soap recipe (change a fragrance, colour, fragrance supplier etc) it will also need to be reassessed. Can I also make a plea for the Food Imitations regs as well - you cannot sell anything that could be mistaken for a food or drink so nothing that looks or smells like a cake or fruit, for example.

Safety assessments and legal compliance (for cosmetics and also for candles/melts) is something I feel strongly about so happy to advise where I can.

 

[The Efficacious Gentleman]

Is it wrong that I always want to ask them for their paperwork, and shop them in if they don't have it? [emoji23][emoji23][emoji23][emoji1745]

 

[LilyJo]

Is it wrong that I always want to ask them for their paperwork, and shop them in if they don't have it? [emoji23][emoji23][emoji23][emoji1745]

I am SOOO glad its not just me

 

[Deadgroovy]

No they dont and they are breaking the law!

Its one of my pet hates and something that has a huge affect on UK/EU soapmakers - there are so many YT or IG posts with recipes and encouragement for people to just go ahead and sell that people think you can just do that. It might be legal in the US or elsewhere but not getting products safety assessed is against the law here, will invalidate your insurance, can prompt seizure and prosecution from TS.

I am with TEG, the portal is pretty simple and once you have your recipes back its straight forward to fill in and upload. Dont forget you will need images of your packaging and will need to update the portal should that change. If you make an amendment to the soap recipe (change a fragrance, colour, fragrance supplier etc) it will also need to be reassessed. Can I also make a plea for the Food Imitations regs as well - you cannot sell anything that could be mistaken for a food or drink so nothing that looks or smells like a cake or fruit, for example.

Safety assessments and legal compliance (for cosmetics and also for candles/melts) is something I feel strongly about so happy to advise where I can.

TEG? Can you enlighten me?
I'm looking to maybe start selling in 6 months time and of course want everything to be legal and above board. I've been to a couple of craft shows and have seen people selling their soaps and have thought about wether or not they are fully compliant.

 

[LilyJo]

TEG? Can you enlighten me?
I'm looking to maybe start selling in 6 months time and of course want everything to be legal and above board. I've been to a couple of craft shows and have seen people selling their soaps and have thought about wether or not they are fully compliant.

TEG - The Efficacious Gentleman!

Tbh you can often tell by looking at the labels and whether the labels complies!

 

[Deadgroovy]

TEG - The Efficacious Gentleman!

Tbh you can often tell by looking at the labels and whether the labels complies!

Stupid me! And thanks for your advice
I'm also in the process of putting together my PIF and GMP documents/statements.
Any help and advice would be more than welcome.

 

[JuliaNegusuk]

Hi. I recently (a couple of years ago) went on the portal. It looks horrendous, is very time consuming but isn't as bad as it seems once you get started. Once you have done one soap, the others are just the same process over again. My advice, get all the bits and pieces, the attachments and photos all ready and set aside an afternoon and get it all done. You don't need to do it again unless you make a change.

It drives me mad seeing people who are not certified. It particularly annoys me when you see sellers accidentally forgetting to mention that sodium hydroxide is included in the recipe? It's quite amazing how often you see this - and I don't mean sellers that use the latin terms (eg sodium cocoate or sodium olivate for example) they just don't mention it at all!

 

[Deadgroovy]

Hi. I recently (a couple of years ago) went on the portal. It looks horrendous, is very time consuming but isn't as bad as it seems once you get started. Once you have done one soap, the others are just the same process over again. My advice, get all the bits and pieces, the attachments and photos all ready and set aside an afternoon and get it all done. You don't need to do it again unless you make a change.

It drives me mad seeing people who are not certified. It particularly annoys me when you see sellers accidentally forgetting to mention that sodium hydroxide is included in the recipe? It's quite amazing how often you see this - and I don't mean sellers that use the latin terms (eg sodium cocoate or sodium olivate for example) they just don't mention it at all!

Correct me if I'm wrong, but I don't think you have to declare the sodium hydroxide because the sapifocation process converts the oils to soap (I know, a bit of a simplification!) and you only have to label whats in your finished soap, no SH because there is none there,

 

[JuliaNegusuk]

There are different ways of listing ingredients. If you are using the method listing what the soap is made of after it is made, you are correct, you label the finished soap, which should be described as I stated above - sodium cocoate, sodium olivate, sodium tallowate etc. The words sodium hydroxide aren't there, but you can still see the word sodium in the description. You can also list the ingredients just by the oils eg olive oil, coconut oil, tallow etc. If you do this then you are listing the ingredients before they end up as soap, so sodium hydroxide should be a separately listed ingredient. Also if I remember rightly (I do it the other way so I can't quite remember) but I think if you use the "before" method you have to use the latin or international terminology as well as the "english" words not the english words on their own. So oliva europaea, or cocus nucifera for olive oil and coconut oil. I also recall having to do this for the EU Portal. I do find I come across sellers who use the "before" method without including sodium hydroxide, which makes their ingredients list sound nice and natural, but isn't correctly describing the soap. And is illegal.

It is however quite possible I'm wrong and I'm sure someone tell me, but I looked into it all quite extensively at the time but my memory is fading a bit as I'm just now sticking to my recipes and getting on with it.

INCI names -that's what I was trying to remember. As I recall you will need these for the EU Portal and, if you do choose the "before" method - on your labels too.

 

[Deadgroovy]

I have designed and printed some prototype labels and have used the INCI names as followed:

Ingredients: Olive Oil (Sodium Olivate), Palm Oil(Sodium Palmate), Coconut Oil (Cocos Nucifera), Aqua, Sweet Almond Oil (Prunus Dulcis), Castor Oil(Ricinus Communis), Ginger Essential Oil (Zingiber Officinale), Bergamot Essential Oil (Citrus Bergamia), Patchouli Essential Oil (Pogostemon Cablin)

It's definitely a bit of a minefield trying to do the right thing!

 

[JuliaNegusuk]

Mmmm. You are doing a combination of both the before method and the after method! I really don't know if that's ok or not. Personally, I kind of feel that you should still identify the sodium hydroxide in english if you are doing the rest in english. I feel you are being a bit disenguous if you don't. But then I am an ex civil servant and a bit of a stickler! You also need to check your essential oils to see if they contain any allergens that need to be seperately identified. Not all have them, but some do and have really horrible, long chemical sounding names that really muck up your labels.

 

[Chris_S]

Very interesting post would there be any chance this could be pinned to make it easy for those selling or wanting to sell in the eu to see the regs and discuss any concerns they might have.

Im not ready for selling yet but even though im only giving as testers and gifts for feedback iv made a label granted it wont be complient to selling regs but i decided it was important to list any ingridients just in case someone has an allergy. What i have done is made them into a little leaflet which explains about the use of lye but it not being in the final product so the users are aware and can see it wont be causing any harm to the final user. I like this idea and when i hopfully do get round to selling will likely be doing this regardless of whether its included on the label as i think its important for these things to be made aware to the buyer. The leaflet also has simple care guidelines to help the buyer get the best out of the soap like using a drained soap dish and letting it dry out between uses especially when used in the shower iv done the same with my candles and melt again not selling but even as gifts and samples feel its important to tell people these things.

@LilyJo when you say it cant smell like food how on earth can you sell something like a choc orange candle or wax melt? Surely the fact that its clearly a candle and looks nothing like a choc orange means it cant be mistaken for the chocolate sweet as long as you dont go making it in the shape of orange pieces? Companies sell them for use in candles right?

 

[Deadgroovy]

Here is an example and explanation from the company that is doing the testing on my soap:

Cold process and Hot process Soaps - labelling
Example recipe –
300g Coconut Oil
300g Palm Oil
300g Olive Oil
100g Castor Oil
143.1g Sodium Hydroxide
380 g Water
During the manufacturing procedure (saponification) the oils in the above recipe are converted to the sodium salts
(soaps). Glycerine is also formed during the reaction.

Fat/Oil + NaOH > Glycerine + Soap
1 g NaOH produces 0.77g Glycerine in the soaping reaction.
1 g Oil/fat produces approximately 1 g of soap salt
Excess water is lost during the curing process leaving final concentration of around 8.5 - 12.5 % of the initial weight of oils.,
depending on cure time. As a general rule, water should be above glycerin on your labels - as per the example below.
So, in the final product, we will have
Sodium Cocoate, Sodium Palmate, Sodium Olivate – 300g each (900g total)
Sodium Castorate – 100g
Glycerine – 110.2g
Water 125g

As a simple guide, when using 1000g of oils/fats/butters etc. The sodium salts of those present in the initial recipe at
less than 100g should go after water and glycerine on the list of ingredients.
So this basic product would be labelled as follows:
Sodium Cocoate, Sodium Palmate, Sodium Olivate, Aqua, Glycerine, Sodium Castorate.
Now let’s include the essential oils, lavender, at 1%, sandalwood, at 0,5% and sweet orange at 1%
300g Coconut Oil
300g Palm Oil
300g Olive Oil
100g Castor Oil
143.1g Sodium Hydroxide
380 g Water
10g lavender Essential Oil
5g Sandalwood Essential Oil
10g Sweet Orange Essential Oil
The ingredient list would now read
Sodium Cocoate, Sodium Palmate, Sodium Olivate, Aqua, Glycerine, Sodium Castorate, Lavandula angustifolia oil,
Santalum Album Wood Oil, Citrus Sinensis Peel Oil.

BUT
We also need to think about Allergens
Lavender essential oil contains the following allergens:
Geraniol - 1,1%
Limonene - 1%
Linalool - 45%
In lavender we have:
Geraniol is present at (1,1% x 1%) = 0.011% in the final product
Limonene is present at (1% x 1%) = 0.01% in the final product
Linalool is present at (45% x 1%) = 0.45% in the final product
Sandalwood Essential Oil doesn’t contain any allergen but Sweet orange Essential Oil contains as follows:
Citral – 0,1%
Limonene - 95%
Linalool - 0,4%
In Sweet Orange we have:
Citral is present at (0,1% x 1%) = 0.001% in the final product
Limonene is present at (95% x 1%) = 0.95% in the final product
Linalool is present at (0,4% x 1%) = 0.004% in the final product
As this is a rinse off product, only Geraniol, Limonene and Linalool will need to be labelled, because they are present
above 0.01%, so our final ingredients label read:

Sodium Cocoate, Sodium Palmate, Sodium Olivate, Aqua, Glycerine, Sodium Castorate, Lavandula angustifolia oil,
Santalum Album Wood Oil, Citrus Sinensis Peel Oil (the names of the essential oils can be replaced by Parfum),
Geraniol, Limonene, Linalool.

Example Label for this product
Countryside Soap
Handmade
With Pure Essential Oils
110ge
Ingredients :Sodium Cocoate, Sodium Palmate,Sodium Olivate,
Aqua, Glycerine, Sodium Castorate, Lavandula Agustifolia Oil,
Santalum Album Wood Oil, Citrus Sinensis Peel Oil, Geraniol,
Limonene, Linalool.
For external use only. If irritation occurs discontinue use.
Batch Number 050909LS COMPANY NAME & CONTACT

 

[The Efficacious Gentleman]

Exactly. Inci, problematic components of the Eos listed. Looks pretty standard to me