Terms and conditions when labelling our products under your own brand, labelling advice, safety assessment / report information and more
Here at Wholesale Handmade Soap we give you the option to buy our potted and bottled products and soap unlabelled for you to add your own labelling if you wish. Due to new regulations that came in to force recently, there are some guidelines that you must abide by to sell products legally in the UK / EU and we explain them fully here. In this article we also give advice on the CPNP (Cosmetic Product Notification Portal), what information your own labelling should legally contain, details regarding cosmetic product safety reports and your responsibilities regarding insurance.
Your responsibilities as a re-seller with regards to the CPNP:
The simple rule is, if you are selling products with our labels on you do not have any responsibilities with regards to registering products on the CPNP, as manufacturers all of our products are pre-registered on the CPNP by us.
- All products for sale in the UK / EU must be registered on the CPNP (Central Product Notification Portal)
- All products for sale in the UK / EU must have a ‘responsible person’ assigned to them to enable the product to be traced and for the purpose of gaining information regarding that product. The responsible person for all products manufactured by The Soap Shop Ltd is Faye Rogerson.
ALL OF OUR PRODUCTS ARE REGISTERED ON THE PORTAL. As a re-seller, or retailer, you do not need to register any product you buy from us on the portal yourself. The portal is for manufacturers only. The purpose of the portal is for government authority or poison control to access information such as ingredients contained in a product. If a product was ingested, for example, a hospital may need to know specific information about the product and it’s composition. To register a product on the portal, a safety assessment is needed.
ALL OF OUR PRODUCTS ARE FULLY CERTIFIED with individual Cosmetic Product Safety Reports in line with the current European Cosmetic Regulation EC 1223/2009.
As manufacturers, we reserve the right to act as the ‘Responsible Person’ for all of our products. This makes sense, as we can very quickly give any information needed about a product, especially in an emergency, because we manufacture the products and know everything that they contain.
I want to label a product myself, what information do I have to include on my labelling?
If you purchase any product from us with the intention of putting your own branding or labelling on the product you must include our details on the label as the manufacturer.
Text such as ‘Handmade in the UK for (*insert your business name here*) by The Soap Shop Ltd LU13PE’ is a good example of what must be on your label.
Other information your must include is as follows:
- Product name
- Full ingredients listing including allergens and INCI names (Full ingredient information for every product is sent to you when you order).
- A batch number (We provide you with a batch number for every product you purchase from us which you can easily transfer to your own labels).
- A ‘period after opening / PAO symbol’ stating the appropriate timescale for that particular product – Soap Bars for example have a 36 month shelf life, so the PAO symbol should state ’36M’ – Please see the picture below for an example of the correct symbol to use. Different products have different shelf lives and we state the correct time limits for our products along side the ingredients in our customer area. In the European Union, cosmetic products with a shelf life of less than 36 months are not required to carry a ‘best before date’. Instead, there has to be an indication of the period of time after opening for which the product can be used without any harm to the consumer.
This is the correct Period After Opening symbol to use on your labelling. All of our products have a shelf life of 36 months or under, so this is the only symbol you will ever need to use on your labelling. There are different guidelines for products that have a longer shelf life.
- The product weight – with potted and bottled products you will have the weights supplied by us and you can use these weights on your labelling, however if you are cutting up soap into different sized bars to wrap, it is important that you use trade approved scales to measure the weight before printing it on to your labelling. It is recommended that you purchase accurate scales that are pre-collaborated in accordance with trading standards. A quick google search will provide you with many suppliers of trade approved scales.
- Any usage insructions or warnings – ‘Avoid contact with eyes’ or ‘Do not eat’ are very common warnings on cosmetic labels. None of our products are recommended for use directly on the eyes. Common sense is all that is needed to provide appropriate warnings.
- As above, you must state our details on the label as the manufacturer, but this does not mean you cannot include your own business name, or website address!
You must then send us a clear photo or photos (1 or 2 is fine as long as we can clearly see the labelling, please take photos in daylight if possible) of the product with your label on, so we can register it on the portal under our pre-existing details as a ‘variant’. This ensures full traceability back to us as the manufacturers. Please note, we do not charge for registering your labelling on the portal.
We always recommend that you check the advise above with your local trading standards department, as we have found that different officers in different areas do tend to give slightly different advice, that being said the guidance we have provided above is pretty standard in all areas. Remember, trading standards are there to help you, not hinder you and they are always more than happy to provide sound advice on all aspects of selling, such as labelling.
Can I take your potted or bottled products out of their containers and put them into my own bottles? Do you supply in bulk so I can bottle or pot my own products?
Currently, we do not allow the re-packaging of our already packaged products. The material that a product is packaged in is considered and assessed in detail within each product’s Cosmetic Product Safety Report. Therefore, our products are only assessed in the packaging that they arrive to you in. Our products have been tested for stability in their current packaging, and removing them from their original packaging will render the Cosmetic Product Safety Report void, meaning the product would be being sold illegally. Different types of plastics or metal plated containers DO react differently with different essential oils and fragrance oils, just because you have a product in a plastic pot does not automatically mean it can be re-packaged into another plastic pot. Some essential oils will actually corrode some types of plastics!
If you have purchased Dead Sea Salts in Bulk please ensure you discuss packaging with us.
Do I need insurance to sell products?
To sell at craft fairs or markets, or even within your own shop, you do need to have ‘public liability insurance’. It is fairly cheap and is essential should a customer have an accident whilst at your stall, or in your shop. Most craft fair organisers or market managers will ask you for evidence of your public liability insurance. A google search will provide you with many options for gaining insurance.
As manufacturers, we hold a full and comprehensive insurance policy covering our products, therefore you do not need ‘product liability insurance’. We are always happy to provide details of this insurance should you ever need it. Please just send us an email and we will be happy to assist you.
Please note: If you fail to abide by the above guidelines regarding the CPNP, we cannot accept any responsibility for any action against you by any governing body, such as trading standards. To sell a labelled product that has not been registered on the CPNP is illegal, so please do make it a priortiy to get your photographs sent over to us for registration as soon as you possibly can. We aim to register all products with your labelling within seven working days. Ultimately, it is your responsibility to ensure you are abiding by law and your local trading standards department guidelines. The advice on this page is meant as guidance only, and it is your responsibility to check with your local trading standards officer to ensure you are conforming to the correct guidelines for selling cosmetic products.