You make a homemade wonderful herbal moisturizer and give it to your friends. They’re all taken aback by its effects, and you’ll logically think “why not make a living from it”?
Why not! However, you will need to keep enough of that enthusiasm. The road to your own certified moisturizer will be a long one. Bringing a product to market and complying with all legislation and regulations is quite complex, but not impossible. The production of cosmetic products has quite understandably strict criteria. General health is concerned, after all.
Establishing a trade certificate
We will skip the simplest part, which is setting up a business license. You get the license issued for unqualified trade at the trade office you fall under. Write “Manufacture of chemicals, fibres and preparations and cosmetics” in the appropriate box of your trade certificate registration documents. You will be done in one day. If you already have a trade certificate, you just add in other activities.
First, familiarize yourself with Law No. 258/2000 Coll., on the protection of public health and Regulation No. 1223/2009 on cosmetic products. These are the alpha and omega of your future business. And we’re going to plunge right into the maelstrom of law.
GS tip: It’s prudent to study a few educational publications, articles and tutorials. It will keep you informed and know what questions to ask in the workplace of the sanitation station where your moisturizer-making journey should begin.
If you’ve been stirring your moisturizer in a pot on the stove, filling it into containers on the kitchen counter and storing it in the fridge with groceries, know that you’re not going to live up to the strict hygienic demands. You need to figure out where you want to have your workshop.
Do you truly want it at home? Or would you rather rent some other space? In both cases, you will have to rebuild. Count on a workshop of at least 16 m2 and having to meet several different requirements.
GS tip: Please do not do the “build, arrange and see” method. Best-case scenario, you’ll be demolishing and remodelling. It is ideal to meet the hygiene requirements of the workshop right away, as you will save yourself money and nerves. So first, visit the appropriate sanitation department, make an appointment, consult with them on the situation, and then get to work – builder’s work for now.
Product approval and certification
We will now move quite a bit to “The workshop has been approved and built. We can start manufacturing now.”
You can now make the product, yes, but before you officially release it on the market, it must go through a mandatory examination, which is an assessment of the safety of the cosmetic product in relation to the health of individuals. Where are such examinations carried out?
The easiest thing to do is to contact the National Reference Centre for Cosmetics. Each product must be tested separately. This also applies to variants of your moisturiser. You can’t do without paperwork, of course. Each product which you will be applying for certification must have its own file with name, and a detailed ingredients list of the moisturizer including a safety data sheet.
The safety data sheet is a percentage table of ingredients, or sub-ingredients used. In addition, if some of the ingredients of your moisturizer are herbs, you need to specify their extracts precisely. Indicate what part of the plant you are using, with the help of which reagent and by what process. The extract needs to be accurately described – its smell and colour and also further substantiate toxicological data.
In the case of dry herbs, things will be a little different again. You have to describe the size of the cut-up parts of the plants, etc. You also need to describe the entire production process of the moisturizer. However, we are getting into the details now.
Your moisturizer will go through a special process and pass open epicutaneous testing for instance. What is epicutaneous testing? It is a dermatologic test, which is used for cosmetic products that remain on the skin. They are tested undiluted in a closed epicutaneous testing process, where the excess product is placed in a mini-reservoir on a special patch, applied to the skin and left on for 2-24 hours.
The packaging must meet strictly specified requirements as well. The container for the moisturizer must be non-toxic and have correct labels with a list of allergens, ingredients, but also data about the manufacturer, shelf life, etc.
GS tip: If your moisturizer is packed in two packages, for example in a glass container which is put into a paper box, all mandatory information must be provided on both.
Expect the complete approval process to take roughly two to three months. In the meantime, you can polish the production, fine-tune the label with your graphics, and prepare for more mandatory approvals. This puts your moisturisers in the CPNP. And what is that? The European portal CPNP – Cosmetic Products Notification Portal is a portal for the reporting of beauty products.
It was created to implement regulation (EC) No. 1223/2009 on cosmetic products. Any cosmetic product that is placed on the market of any of the EU Member States must be registered in CPNP. The product is registered by the manufacturer or distributor of the product.
Information on registration in the CPNP is accessible to the relevant state authorities allowing for the supervision of the health safety of products and protection against counterfeiting. The information is also accessible to toxicology centres and other similar institutions in individual EU member states, for the purpose of medical treatment and consumer safety.
To successfully register to the CPNP, it is needed to deliver the exact composition of a product with safety data sheets belonging to the individual raw materials of which the product is composed, along with a sample of the product, to the approving authorities. The product sample is then tested to determine if the product is safe for consumers and contains what is declared on the packaging.
GS tip: There are also optional CPK (a Czech label for certified natural cosmetics) and CPK bio (organic cosmetics), vegan certificate, and HCS leaping bunny certificate (the product is not tested on animals). Learn more on Svoboda zvířat (a website of a Czech national non-profit organisation for the protection of animal rights). Nowadays favours products which are natural, safe, and environmentally friendly and every quality certificate you provide for the product will add value to your customer.
List of recommended literature
Hygiene rules for the production of cosmetics ČSN ISO 2271
Regulation 655/2013 about what information must and must not be included on the packaging of the cosmetic product
The cosmetic product safety report (examples can be found online)