All our soaps (our brand "Renas-Naturals" have a copyright and are certified. Here is some advise if you like to sell your soaps.

ADVICE ON 'CERTIFICATION' OF SOAPS ETC.?

We regularly hand out advice on the need to 'certify' your soaps and other products if you choose to sell them to the public. Because of the widely varying advice available elsewhere and the 'scaremongery' that is put about, we have decided to place this page on our site to advise you, based upon our own experience and understanding of the legislation as it now stands and after having discussed the matter with our main suppliers of soap and toiletry bases, together with the laboratory that tests these bases for the manufacturer. It must be said that opinions and interpretation vary and this is the interpretation of our main supplier of soap bases.

Current legislation requires the makers of soaps and toiletries to demonstrate 'due diligence' in the preparation of their products. This is mainly aimed at mitigating any risk to the individual or company as a result of legal action being brought against them due to any adverse reaction someone may experience when having used their product. Although it is unlikely that any such adverse reaction may be experienced if making soaps and toiletries using pre-prepared bases (melt & pour soap base for instance), the risk is still there. The person wishing to sell their soaps and/or toiletries to the public, even when using a pre-prepared base, does need a 'certificate' (safety assessment) to state that the product has been tested and meets required standards. This legislation also requires the full preparation of a product file which should contain all information regarding manufacturing method, ingredients, MSDS for all ingredients etc. This file should be kept available for view by anyone requesting.

Each 'batch' of product should be issued with a batch number and have full ingredients and origin of ingredients record written and kept for scrutiny if required. Batch numbers should appear on any product labeling .Labeling. of all products should comply with INCI legislation, which states that the INCI names for ingredients should be labeled clearly and legibly either on the product packaging, or where not appropriate, maybe because of size, should be clearly visible at the point of display. Ingredients should use approved INCI names for each one. Ingredients should be listed in descending order of weight as they are included in the manufacture of the product and should use the INCI names for each ingredient used, with certain exceptions such as for a naturally saponified soap, which would have oils and lye added together in manufacture, but would not have any significant amounts of either oils nor lye remaining in the final soaps, so in this case the ingredients are listed in terminology relating to the finished substances. E.G. Soap made from Olive Oil and Lye would be listed as 'Sodium Olivate'. There is no need to refer to oils as their INCI names nor to Lye (Sodium Hydroxide), as it is not present in the finished soap. Ingredients in 1% or less concentration can appear in any order at the end of the list. More recently, certain allergens present in many essential oils and fragrance oils need to be included in the INCI labeling. in cases where they exceed 0.01% in rinse-off products (soaps, shampoos etc.) and in 0.001% in leave-on products (moisturizing creams etc.). Separate advice for this legislation is available in your country of production. Please talk to Trading Standards or your Trade and Registration offices which should be able to point you in the right direction.

Product labeling. should also include a 'point of contact' address for the manufacturer (you).

The 'gray' area that exists in this legislation and which affects small manufacturers the most, is whether a different certificate is required for EVERY variation of a product made with a particular base. Strictly, if any change is made then a new safety assessment is required, but the legislation is open to interpretation. An approved laboratory offering product assessment can offer 1 assessment covering a large number of variations on a product. For example, if you are using one soap base but creating 20 different soaps by varying fragrance, enrichment and colour, a laboratory can offer to incorporate all the variations in one assessment. This has a beneficial effect on the cost, as typically each assessment will have a minimum price and be incremented per ingredient tested, so incorporating all variations on a product in one assessment means only one minimum charge .However some countries e.g. Germany might require a certification for every single variation, so do find out there before you sell.

There can also be further savings if you're using pre-manufactured bases, where you use a laboratory that is already familiar with the product, for your own assessment on your finished product/s. They may be able to offer a reduced price for assessing variations on the particular base because they already assessed the base itself or products already using the same base, so they could offer to incorporate a base product as a single ingredient in an assessment, rather than the long list of ingredients within that base having to be charged for individually in the testing again.

Watch out for companies offering "Pre Certified" Products. There is no such thing as a pre-certified product. The legislation clearly states that the test has to be done on the finished product as it is offered for sale to the public. If you are using so-called pre-certified products then you are probably wasting your money, as the safety assessment would probably not stand up in a case of litigation against you, which is the whole point of having your products properly safety-assessed in the first place.

There is no time limit on a safety assessment. Once completed, your assessment is valid forever. It does not require annual renewal.

As a supplier to many individuals and small businesses we feel an obligation to provide accurate information and also to give our customers access to cost effective professional advice and safety-assessment facilities in order for them to AFFORD to 'certificate' their products.

It is important to ensure that whatever organization you use to safety-assess your products, they have proper and adequate Professional Indemnity insurance, because without this, should you ever have to call upon them as a defense in litigation, you may find they are not able nor willing to act in your defense

The DTI and Trading Standards can provide fuller information on the legislation and how to comply.

Information on the listing of allergens in finished products is available here.

Useful Web Page giving INCI names for common ingredients, here.

THESE GUIDELINES ARE BASED UPON OUR OWN EXPERIENCES AND UNDERSTANDING OF THE LAW AS IT STANDS