I'm not quite sure where to post this question but here goes...
My plan is to have my base soap recipe (with variants) assessed to comply with EU regulations sometime in the next couple of months. I have a fairly good understanding of all the regulations required by the EU. However, today I come across more regulations required specifically in Spain in the manufacture of soap and my head is spinning!
I've been searching and reading online all afternoon. It seems like in addition to EU regulations, any cosmetic manufacturer within Spain has to obtain permission from the Spanish Agency of Medicines and Health Products (AEMPS). I have seen reference to fees (over 700 euros) and numerous 'inspections'. Approval requires that the manufacturing process (regardless of how big or small the producer is) be overseen by a qualified technician (a chemist?? I've seen reference to this being someone with a science degree?) and that the facilities are adequate for the manufacture of soap.
I don't know if this qualified technician is simply a qualified person periodically 'signing off' that the process you have in place is not hazardous or if it means that the soap manufacturer has to have a qualified person present all the time soap is made, effectively an employee. Neither do I know how they define adequate facilities for the manufacture of soap. Can you have adequate facilities in your house? Do you have to have a dedicated workshop or something even more technical/formal?
Many of the documents I have looked at are official regulation documents which are written in formal 'legal' Spanish which I'm told can be confusing even for native speakers! I speak Spanish (more or less) but this is a stretch for me!
So....to anyone in Spain who has any knowledge or experience of this, or who can recommend a resource/information/help, I would be SO grateful. I'm beginning to think that being a small producer here may simply not be possible!
Thank you.
My plan is to have my base soap recipe (with variants) assessed to comply with EU regulations sometime in the next couple of months. I have a fairly good understanding of all the regulations required by the EU. However, today I come across more regulations required specifically in Spain in the manufacture of soap and my head is spinning!
I've been searching and reading online all afternoon. It seems like in addition to EU regulations, any cosmetic manufacturer within Spain has to obtain permission from the Spanish Agency of Medicines and Health Products (AEMPS). I have seen reference to fees (over 700 euros) and numerous 'inspections'. Approval requires that the manufacturing process (regardless of how big or small the producer is) be overseen by a qualified technician (a chemist?? I've seen reference to this being someone with a science degree?) and that the facilities are adequate for the manufacture of soap.
I don't know if this qualified technician is simply a qualified person periodically 'signing off' that the process you have in place is not hazardous or if it means that the soap manufacturer has to have a qualified person present all the time soap is made, effectively an employee. Neither do I know how they define adequate facilities for the manufacture of soap. Can you have adequate facilities in your house? Do you have to have a dedicated workshop or something even more technical/formal?
Many of the documents I have looked at are official regulation documents which are written in formal 'legal' Spanish which I'm told can be confusing even for native speakers! I speak Spanish (more or less) but this is a stretch for me!
So....to anyone in Spain who has any knowledge or experience of this, or who can recommend a resource/information/help, I would be SO grateful. I'm beginning to think that being a small producer here may simply not be possible!
Thank you.