Entering the murky world of EU regulations

[Saponista]

I'm wondering where you found the regulation about molecular weights @efficacious gentleman I haven't seen anything about that myself and any of the handmade soap I have looked at doesn't have that on the label, is it something to do with the EU portal submissions? Molarity is really easy to work out, I do it all the time at work. Most solution recipes give you the ingredients in molarity. You'll find all the info you need on an a-level chem website. If you reach a point where you need help just give me a shout.

I have been looking a bit more deeply into cosmetics assessments, the company which seems to be most widely used in the UK quoted me £179 for one simple anhydrous base recipe with 6 variations to that recipe eg scent and colour. Each variation can have a max of 5 different ingredients. The company basically said that along with that price they would help with sorting everything to get my business sorted and legal.

There is another option as many of the soap supply companies offer 'off the shelf' assessments. One company offers an assessment from the same company above which includes 8 variations rather than 6 for only £165 but you are basically on your own with regards to complying with the rest of the regulations and to a certain extent you are required to use their ingredients in your products which would make keeping costs down difficult.

There is some interesting info on this page though

http://www.bathbomb.biz/acatalog/Cosmetic_Safety_Assessment_Packages.html

There is a list of common approved ingredients and accepted % usages so it might be worthwhile checking if your recipes fit within those parameters before going to get them assessed.

I'm still no further on with working out how to calculate best before dates for my soaps and the regulatory company were really cagey about giving me help with that before I handed over any money to them.

 

[The Efficacious Gentleman]

The molecular info was more based on using nanites or some such (don't the Borg use nanites? Freaky) but for normal soaps and things it doesn't seem to be needed. Which is a good thing!

As for the asessments, I thought that each ingredient had to be approved and that you could use that as you wanted - so if you had 10 oils and 10 colours approved, you could make mixes using these in combination? I am still working towards getting good information on what I would need to do about my process/location for soap making before I worry too much about recipes, though.

The first option sounds best if you can use your preferred ingredients. The second option sounds like a supplier tying you in to an agreement! Also look at how much they charge for single ingredients, in case you want to change from one CO to another, for example.

 

[Saponista]

I think getting each ingredient approved and using them in any combination worked previously but the new regs that came in in 2013 seem to have put a stop to that as far as i can tell. The new thing seems to be that you have to have each recipe assessed and accepted which sucks as it means that creativity is stifled. Especially for small craft businesses.

 

[Saponista]

Oh and I think the nanites might have something to do with nanoparticles. Loads of cosmetic glitters and oxides now have to be labelled as nanoparticles if they are a certain size. There seem to be environmental issues with them bioaccumulating in things like shellfish.

 

[The Efficacious Gentleman]

Wow, that is very pants! Makes sense in some ways - you can't just use any amounts of lye, for example! But not so great in other ways.

If that is the case, the costs should be some what lower, I think. I hope!

 

[Saponista]

I still can't believe your €600 fee just for some info!

 

[The Efficacious Gentleman]

Indeed! It's madness to expect me to pay just to find out what will be expected in the process.

I have found the name of another company, will see how helpful they can be. Sending them an email this evening about it and hope that I can get the full information and then decide if it's an option for me or not.

 

[Saponista]

I hope you get all the info you need are you considering soap selling as your only income or are you still planning to work at whatever it is you do at the moment?

 

[The Efficacious Gentleman]

What I do at the moment seems to be sitting in the office looking at SMF

But to start with, it will be supplimenting. Once I know that it is possible, I'll get my recipes sorted and go to local chemists shops - they are independant here and can decide what they sell at a local level. I'll see what they are interested in and go from there. An initial order that goes some way to offsetting the start up costs would make it a better option.

Of course, once the recipe and all that is signed off, the reg costs are over and then I can make 100 batches and do the PIPs myself so there are no more costs involved unless I want to change a recipe.

I would like to have it be the main income, though.

 

[Saponista]

I am also sat at work on SMF lol! Dreaming of the day I can break the ties and work for myself. I dropped down to 4 days a week so I now have Fridays off to experiment but I still need cash to buy stuff to experiment with.

 

[Saponista]

You could try crowd sourcing to get some money to start up.

 

[The Efficacious Gentleman]

To clarify on the other post - I'll take some samples to market and see what people like and don't like, beyond my testing friends and family. No point getting a recipe signed off if no one actually wants to buy it!

 

[Saponista]

That's the difficulty isn't it because you can't give it away to anyone other than friends and family without a safety cert. which makes market research nigh on impossible.

 

[The Efficacious Gentleman]

As I read it, I can't sell soap to the general public. Giving a gift to a chemist to see if they want to stock it is another thing............................

 

[Saponista]

I guess that still falls under the friends and family thing, as you aren't actually selling it to them.

 

[Lindy]

My understanding of your SA is that you will have a list of oils and additives with the maximum allowed percentages so you can play with your recipes. If you need more additives then there is a charge for each one added to your SA. I hope that helps you out...

 

[The Efficacious Gentleman]

Thanks, Lindy.

The recipe side of things is not too bad, but the actual production process requirements that could be the problem - Do I need to use an extra "kitchen" with hot running water or is my normal kitchen okay or do I need another room but with cold water.....................until that is answered I won't know if it is a viable plan or not

 

[Yill]

I have received an example of a PIF which also contains GMP. I still find it quite hard to understand how that translates into the way you should set up your soaping kitchen in order to comply to the rules. ISO 22716 is al about GMP, but I still have to read it, it's loooong lol. I wish there was just a simple document that would explain what you need to do to get the production process in order. Like: Have a separte kitchen, use only stainless steel utensils, use only laboratory glass pitchers, keep your oils in a cool dark place, keep your EO's stored in a dark cabinet etc. etc.

I completely understand Gentleman's process I'm following the same route!

 

[The Efficacious Gentleman]

Welcome to the world of pain

The biggest issue is that there is an EU legislation with the MINIMUM requirements - each member state can add on to it anything that they fancy. That's why we have the example of the UK being allowed to use the usual kitchen but in Germany the goverment added the requirement of a different room.

Hopefully the company I emailed last night can shed some light on things. Failing that, there is a kind of Trading Standards body here in Austria that I can try - knocking off the options as I go, but also find more options that are potentially more helpful!

 

[Saponista]

The worst is that I seem to get a different answer from each different person I contact.