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Australian soap making regulations

Discussion in 'Labels and Packaging' started by SaltedFig, Oct 11, 2017.

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  1. Oct 11, 2017 #1

    SaltedFig

    SaltedFig

    SaltedFig

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    In Australia, there's a bit of legal stuff you will need to know about before you begin to sell. I've included the links to the labeling regulations as well as a list of the other laws and regulations you will need to know, so you can work your way through them (don't panic, it's not as bad as it first looks!).

    Before you sell:

    Register with NICNAS
    to make soap (see https://www.nicnas.gov.au/cosmetics-...nd-soap-making) and pay yearly licensing fees.

    Register your business (optional, but you'll need that at a lot of places to get wholesale prices on bulk supplies). You don't need GST registration straight away (until your big enough - talk to an accountant)

    Get business insurance, specific to manufacturing soap (hard to get sometimes - talk to a broker or another local soaper)

    Try and find a commercial kitchen to work from (and if you are renting, this gets very important), and always be prepared for a site inspection.

    Read up on labeling laws (see https://www.productsafety.gov.au/sta...ents-labelling)

    And whatever you do, don't ever make a medical claim - that will throw you out of the Cosmetics category and into Therapeutic Goods, which brings you under the authority of the TGA (Therapeutic Goods Administration), and you really don't want that - the compliance and testing requirements are well beyond most small businesses.

    There are some other laws that might be council specific or landlord specific if you are renting that may come into play, but this covers the main (legal) things to think about (and if I've forgotten anything, I'm sure other's will chime in for you).

    After all of that, it's actually the non-legal stuff that has the biggest learning curve ... but it's oh so much FUN! [​IMG]

    Good luck!
     
    Twinmummy2014, Miki and Tais like this.
  2. Oct 11, 2017 #2

    Tais

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    Awesome!

    Thanks so much for this post!!
     
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  3. Oct 11, 2017 #3

    Relle

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  4. Oct 11, 2017 #4

    SaltedFig

    SaltedFig

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    Thanks for fixing the sticky link Relle :) (and that second links a beaut!)
     
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  5. Oct 11, 2017 #5

    Dahila

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    It looks very similar to our Canadian rules. Why people put lye on labels is over my head. In end product there is not lye present anymore, but glycerin is (byproduct) I would not buy soap with Lye present. :)
     
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  6. Oct 11, 2017 #6

    Tais

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    I completely agree with you, but I was always wondering why people do that :)

    Now I am thinking here: should we put glycerin?

     
  7. Oct 12, 2017 #7

    Dahila

    Dahila

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    yes glycerin will Naoh times 0.77 so usually it just after water, I put my water at 10-12% then glycerin 8-9% then in descending order .......
     
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  8. Oct 15, 2017 #8

    Tais

    Tais

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    Thank you for this info!

    Regarding the insurance, do you know/recommend any company here in Australia?

     
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  9. Oct 15, 2017 #9

    cmzaha

    cmzaha

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    Putting lye on the label depends on how you label, if it is what goes into the pot or what comes out of the pot. I go with the first so lye goes on my label and I have never had a customer not buy a soap because of it. If they ask why lye I just give them the short version of what makes soap, Lye, water fats
     
  10. Oct 15, 2017 #10

    penelopejane

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    Any insurance broker will give you a quote.
    Be sitting down when you read it! :headbanging:
     
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  11. Oct 7, 2018 #11

    SavouryBanana

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    I have a question.

    [And before anyone asks - yes, total noob]

    I'm wondering about soap as art?

    I'm a sculptor and was think about (after some trials) casting something soap for a specific message/purpose/piece.

    Would that make a difference to the above?
     
  12. Oct 7, 2018 #12

    SaltedFig

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    It makes some difference, in that all of the of the labelling and listing of ingredients are not necessary; as a sculpture,your soap art is not considered a cosmetic (ordinary bath soap is treated as a cosmetic for labelling and insurance purposes)

    Soap itself is considered an Industrial Chemical, under the Industrial Chemicals (Notification and Assessment) Act 1989
    https://www.legislation.gov.au/Details/C2013C00643, irrespective of the end use.

    I have contacted the Department this morning, to double-check my answer, and yes, you do need to register with NICNAS, as you are manufacturing an Industrial Chemical (soap).
     
  13. Oct 8, 2018 #13

    KimT2au

    KimT2au

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    Thanks for all those links, I am currently working my way through them although I have read them before. One thing I did think was interesting is the debate on whether you need to include lye in your list of ingredients. I am attaching a clipping from an ACCC document which may be relevant. My understanding is that as lye is not present in the final product you do not need to list it. You should, however, label your ingredients as sodium whateverate eg, sodium tallowate for tallow or sodium lardate for lard simply on the basis that neither tallow nor lard are present in the final product, but the sodium version is. Interesting

    An interesting little factoid (well at least interesting to me) concerns dog wash soap. When I first looked into soap making it was with the idea of making my own doggie soap (I am sure I have banged on ad nauseam about my foster dogs and the condition they are often in when I get them straight from the kennels) so I started to research labeling etc for animal soap. If you are marketing for animals you are covered by the labeling requirements of the Department of Primary Industry and, oh boy, there is a website that contains material on a very narrow range of topics. In the end I gave up on the doggie soap idea. I just thought you might find this interesting.

    Kim



    Capture.PNG
     
  14. Oct 8, 2018 #14

    SaltedFig

    SaltedFig

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    Thinking further (and to answer your question more thoroughly) ... if you are casting a soap that is already manufactured (like melt and pour, or a soap base that another soapmaker has made, for instance), then there is no need to register anything, because you are not making it, just casting it.

    The ACCC are interested in soap from the perspective of safety and full disclosure for the consumer.

    They provided these links, which might be useful to you:
    https://www.productsafety.gov.au/standards/cosmetics-ingredients-labelling
    https://www.productsafety.gov.au/sy...labelling on cosmetics - Supplier guide_0.pdf

    My opinion:
    Personally? I would still list the input ingredients.
    Listing the products of the reactions could get quite complex quite quickly, and could expose you to claims of non-disclosure.

    One of the advantages of making soap using industrial methods (where the soap noodles are made first, then they are processed with the other ingredients and formed into bars) is you get the best of both worlds - the ingredients are fully disclosed, but can be listed as the -ates (Sodium palmate etc.) for the soap part, and the additives in their original form for the rest of the ingredients.

    This makes naming simple - eg. the ingredient list for a simple palm and olive soap with added vinegar would be sodium palmate, sodium olivate and vinegar.
    The same soap in a cold process version? You would need to know what the product of vinegar and sodium hydroxide is, then calculate how much of the product you have made (to name it correctly, and to place it in the correct position in the ingredients list). Simple, perhaps, for one additive, but once you start adding a lot of ingredients that can react with lye, it gets messy pretty quickly.

    ACCC advice:
    The bottom line advice (from the lovely person from the ACCC) ... check with a lawyer, if you want to use chemical products on your label (instead of the ingredients).

    My summary:
    That's not a no, but I would be careful :)
     
  15. Oct 8, 2018 #15

    KimT2au

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