Entering the murky world of EU regulations

[The Efficacious Gentleman]

Some progress! Good news for the Germany-dwelling members here -

"Sie sollten direkt bei den Behörden anfragen. In Deutschland wird es akzeptiert, dass in der Küche gesiedet werden darf. Ob dies in Österreich auch der Fall ist, kann ich leider nicht sagen. Fragen Sie beim Bundesministerium für Gesundheit in Wien."

I received this from a company I emailed last night (top marks for response time!) who are able to work with me in Austria but seem to struggle on the finer points of where I can or can't make soap to sell.

But what the above states is that it IS acceptable to use the same kitchen! I'm sending an email off to the health ministry here is Austria to get the 401, as you Yanks would say.

 

[Lindy]

Gentleman that is so fantastic!!! You have worked hard to get this information and you stuck with it. Yay!

 

[The Efficacious Gentleman]

Thanks, Lindy!

A little bit annoying that there are mixed messages - some places saying you cannot use your kitchen in Germany, others saying you can. Just hope it is the case that I can in Austria. Then my plan is -

Keep working on recipes
When I have some recipes that I really like, contact local independant Chemist shops (Apotheken) in my area and see which ones they would be interested in buying
Get the recipes that the Apotheken want signed off by the EU

That way I am not wasting money getting a recipe signed off if no one is interested in using it.

I wonder what the legal isssues would be of sending a sample of soap that is non-registered to customers when they purchase something else so that they can test it and give feedback? Although in fairness I think often from a customer point of view, it's more about additives, water replacement and scents, once you have a base recipe that is not drying, bubbles well and so on.

 

[Saponista]

I think there might be some difficulties legally as if anything happened to those people using the soap, allergic reaction etc. then you wouldn't have any legal cover. I think you could probably have some samples open on the counter for people to pick up and smell and tell you which scents they would be interested in buying though.

 

[The Efficacious Gentleman]

I've just seen that http://www.cosmeticsafetyassessment.com/ are toying with a very interesting idea - selling completed recipes already signed off! If you don't want to develop your own, or they have something that you don't have in your roster, you can just buy the pre-approved recipe, make it and sell it! Should save a few euros if it is a similar recipe or something totally new that you want to sell but don't want to pay for a custom recipe to be approved.

 

[Saponista]

Where did you see that? Might be a good idea for water based things like creams and lotions that have to be micro tested.

 

[The Efficacious Gentleman]

It was posted on their facebook page

 

[Lindy]

Scott has been doing that for a while with lotions and creams, however, there are some specifications with the type of container you use. They need to be the airless bottles to help with preservation of the lotion otherwise they have to be challenge tested.

 

[Saponista]

Are they ones with a pump top or something then?

 

[Lindy]

They are a pump top but they do have any air in them and as they are use up there is a bottom that comes up in the bottle. There are also airless jars too, although they are expensive.

http://www.newdirectionsaromatics.ca/airless-dispenser-refillable-clear-bottle-with-cap-p-2319.html

 

[The Efficacious Gentleman]

Another update - I have my CPNP access granted! A little bit ahead of time, I know, but it's then aslo something that I can learn before I actually need to use it.

I had some information through from the health ministry here in Austria but it is not overly clear. So I emailed back to the assesor to say that I would do the PIFs/PIPs myself as well as the regular labelling. But I would like to use them for the initial label planning and my recipe sign off (seems to be reasonable costs, will post examples when I am back on my computer) but I also asked if I needed anything else, such as an assessment of my method and location - if I do, then I'll see if they can do this and, if so, what are the requirements.

Of course, in the mean time I'm working on the most important thing - making soap! Even if I can't get to a point of selling it, I'm going to have some kick donkey soaps.

 

[Lindy]

Good for you!

 

[Miz Jenny]

E.G. that's great news! Your donkey soaps will be amazing.

 

[Yill]

That great!

 

[Twiggy]

How on Earth I miss so much updates on that VERY IMPRTAND thread?!?!?!?!

E.G. Wow, you r way ahead of me lol I would love to know which assessor you r in contact with, and what’s the costs, maybe you could PM me about it? I contacted Scott company and when I will have green light from authorities here I’m planning to use them.

So I contacted my Veterinary and Food Safety Office in my region, but I didn’t reach the men responsible. So I’ll try on Monday again.

Also the news on ONE kitchen… I caress my mind with that possibility, but not having much hope that I will be able to use such a chance to create soaps in my own daily used kitchen.

Guys pls tell me what is PIP (some more stuff to take care of) and GMP?

E.G. I really don’t want to put you down, but is better to check such information. I’ve found on german forum such info:
“Für die Österreicher kommt nochmal erschwerend hinzu, dass man bereits eine artverwandte Ausbildung hinter sich haben sollte - z. B. im Laborbereich. Alle anderen müssen eine Zusatzausbildung absolvieren, die nochmal zusätzlichen Zeit- und Geldaufwand erfordert.”

Plus here even you build the extra kitchen, buy extra stuff for it, make it stick to the rules, veterinary office will love it, you must go to some kind of building department and ask them kindly to change your kitchen “usage purpose”, is like to get the allowance to use one of you home rooms to run business there… I think I’ll go crazy – sometimes I think that the goal for government here….

:crazy:

Another update - I have my CPNP access granted! A little bit ahead of time, I know, but it's then aslo something that I can learn before I actually need to use it.

I had some information through from the health ministry here in Austria but it is not overly clear. So I emailed back to the assesor to say that I would do the PIFs/PIPs myself as well as the regular labelling. But I would like to use them for the initial label planning and my recipe sign off (seems to be reasonable costs, will post examples when I am back on my computer) but I also asked if I needed anything else, such as an assessment of my method and location - if I do, then I'll see if they can do this and, if so, what are the requirements.

Of course, in the mean time I'm working on the most important thing - making soap! Even if I can't get to a point of selling it, I'm going to have some kick donkey soaps.

I did exactly the same! I used Scots tips and guides… But I have question, do you get any feedback, that is approved or something, or you just enter your recipe and id than?

 

[The Efficacious Gentleman]

Hmmm, it seems that a lot of the places where we get our advice from seem to have a different idea from the next one! Some assessors say one thing and then a second says something else. It might just be interpretation of the regulations. Hopefully it is just that!

I'll PM you the assessor that I found.

PIP is a Product Information Pack (in PIF, the Pack becomes File) and is just an online record of each batch of soap. Let's say that you get 5 recipes approved, every time you make a batch of any one of these recipes to sell you would need to create a PIP/PIF online - the unique number generated is then your batch number for going on the labels, so that each soap can be traced back to the PIP stored online.

 

[Twiggy]

I think first think we should do is to contact an officer from Amt für Gesundheit und Lebensmittelsicherheit in our area to find out what they would like to in our kitchens, our papers. Assessor know nothing about it, as they will not perform possible controls for us. So for now I contacted one, but we think that he is not the one, who is responsible for my area – he doesn’t know sure himself. So we search.

About the PIF and PIP, I know about to keep records in PIF, is PIP obligatory, or I can stay with traditional paper version which I think PIF is. Is PIP generated in some kind of application, or webpage?
I know the bachnumber you can create yourself.

Thank you for PM.

 

[The Efficacious Gentleman]

You have to register each batch on the CPNP website (http://ec.europa.eu/consumers/sectors/cosmetics/cpnp/index_en.htm - you can select the best language for you there) and use their batch number. As far as I am aware, this is a requirement rather than just filling in a paper version.

 

[Twiggy]

You have to register each batch on the CPNP website (http://ec.europa.eu/consumers/sectors/cosmetics/cpnp/index_en.htm - you can select the best language for you there) and use their batch number. As far as I am aware, this is a requirement rather than just filling in a paper version.

I’ve read those documents last year and find nothing about each batch. I’ve back then registered and entered my soaps recipes. Ok, looks like I’ll reading it again, maybe something has changed (???) Or I’ve maybe overlooked it somehow…

 

[Twiggy]

Ok, so today I’ve succeed to reach my responsible person, and I finally know his requirements for soaping kitchen.