The updated EU Cosmetics Directive and what it means for micro businesses

In July 2013 an updated version of the EU Cosmetics Directive will come into force.

You may not have heard of that or the Directive as such. This is no surprise – it hasn’t been made very public. Certainly the changes have been kept under wraps.

What does this mean for micro businesses working in the cosmetics industry? It could spell the end for some of us. Why? Because it will now not only be expensive to invent and make new products (and established ones for that matter), it will become extraordinarily expensive. What are we talking about? Approximately £350 – £500 for a single product and that is just the bottom estimate. Which product does it affect? Literally all  – whether you make something for your mother, sister, boyfriend free of charge or you sell your skin care to the general public, you will have to comply with Good Manufacturing Practices as well which means – no more mixing and filling in your kitchen as you will have to be able to proof that your equipment and the environment where the products are made  are cleaner than clean, you wear a lab coat, a cap, sterilised gloves and all your equipment is sterile including bottles, jars and caps. Whilst I don’t dispute that this is a good thing and most small-scale manufacturers comply with this already, you will have to state that fact in your PIF file and confirm it with your insurance company (if you have a specialist insurance). And this is where the bug bites – most small-scale manufacturers or businesses who hand make cosmetics will be unable to comply with the very detailed GMPs and their insurance company will refuse to insure their products.

So to sum it up: you will have to comply with the Directive or else you are committing a criminal offense. You will need a state of the art stainless steel work environment and work to lab standards or else your insurance will be null and void. That is as it stands at the moment.

There are one or two organisations who are taking this matter up with the relevant ministry here in the UK and discussions and meetings are ongoing but in my experience once the EU has decided upon a change then there is no going back.

A database has been created where all skin care makers, whether large companies or individuals, will have to register and enter all their products including details with percentages. This is apparently then linked to a central poison centre. I registered on that database 6 months ago and…. nothing. I have not heard back from them nor have I been „approved“.  All makers of skin care have to enter their product details before 13th July 2013. I am not sure how that is going to work if it takes them ages to approve registrants.

What implications does this have for myself? Cebra ethical skin care has been going for 6 years now and I have a great customer base who is informed, trusts me and supports me in my quest to make the best skin care possible. I also have vast knowledge with regards to making natural skin care and I am prepared to pay the fees for certain of our key products. We already work to GMP standards.

However, I may have to rethink our wholesale approach and we may not be able to fulfill special requests such as changing ingredients. The reason for that is that with the upcoming changes I can see ourselves being forced to outsource the manufacture of many of our skin care products  and cosmetics. Which means they are simply not „handmade“ in the true sense any longer and they certainly cannot be „tweaked“ as the production run makes this unaffordable for many of our small retailers who buy specially made skin care just for them from us.

The skin care and cosmetics that I make contain natural or close-to-nature preservatives, they are free from synthetics and aggressive chemicals. From July 2013 I may have to include the one or the other ingredients that may not appear to be 100% „natural“ in order to comply with the EU Directive. Whilst there is a huge hype about any type of preservative for example, it is necessary to give each product a shelf life and to avoid contamination.What we do here at Cebra is introduce new airless bottles and possibly jars so that we need less preservatives. Unfortunately the jars and bottles are made from plastic and not recycled plastic at that. Not yet anyway. Hence I cannot claim that all our skincare is packaged in 100% eco friendy containers, but at least they will be reusable and they are fully recyclable. Glass is not an option as I explained about the drawbacks on that in a previous post and on my Facebook page.

At the same time I shall increase the list of products that are registered with the Vegan Society which give all of you the assurance that all ingredients and all my suppliers have been vetted and that there is nothing in my skin care and cosmetics that has been tested on animals. Of course the end product hasn’t been tested on animals either.

So, if in the future you see things like „Sodium benzoate“ or „Glyceryl stearate“ or „Stearic acid“ then don’t be alarmed. They sound vicious but they are worldwide approved, safe skin care ingredients (some are also certified organic) for mostly water based products to keep bacteria at bay, stabilise an emulsion or make it possible for oil and water to combine.

I shall continue to offer the most natural, vegan friendly, cruelty free skin care with organic ingredients with the help of some excellent laboratories and manufacturers who validate all recipes and perform stability and microbial tests on my skin care products.