When buying a bar of handmade soap, you’re probably thinking about its fragrance, its colours, or its ingredients. You’re probably NOT thinking about toxicology, safety assessments, manufacturing records and cosmetic regulations.
But I am. Quite a lot, actually.
There’s an enormous amount of work that goes on behind the scenes to make sure the soap I sell is safe. So today I thought I’d explain a little about cosmetic safety assessments. Why they’re necessary, and what they mean for you as a customer.
Isn’t soap naturally safe?
You might assume that because traditional soap is made from familiar ingredients such as olive oil, coconut oil and shea butter, it must automatically be safe. But just because an ingredient is plant-derived doesn’t mean it can’t cause irritation or an allergic reaction. Essential oils, for example, contain naturally occurring fragrance compounds, some of which are recognised allergens.
And then there’s the soapmaking process itself. Traditional soap is made using sodium hydroxide, a highly caustic substance that needs to be measured and handled correctly. An badly formulated bar could contain excess free sodium hydroxide, while excessive amounts of particular fragrances or other ingredients could also cause problems.
That’s why making a product that looks lovely isn’t enough. The formulation and the finished product need to be assessed for safety.
What is a Cosmetic Product Safety Report?
In the UK, soap sold for washing your skin is regulated as a cosmetic product. That means it needs to meet the relevant cosmetic safety requirements, just like body lotions, face creams, shampoos and other toiletries. One of those requirements is a Cosmetic Product Safety Report, or CPSR.
A CPSR is a formal assessment of a cosmetic product, carried out by a suitably qualified safety assessor. It’s not simply a certificate you buy to say you’ve attended a soapmaking course, or a piece of paper confirming that your ingredients came from a reputable supplier. The assessor considers the actual formulation, the properties of the ingredients, their concentrations, how the finished product will be used, and the potential risks associated with it.
They also take account of factors such as possible skin irritation, fragrance allergens, exposure to ingredients, product stability and any necessary precautions or warnings.
The aim is to establish whether the product is safe for its intended cosmetic use, and it isn’t optional, it is a legal requirement.
Does every fragrance need a separate assessment?
Yes it does. A cosmetic safety assessment has to cover the exact formulation that’s actually being sold. If a maker changes an ingredient or fragrance outside the scope of their existing assessment, it will need to be re-submitted to the assessor for the changes to be added to the assessment document.
I’m very fortunate to have a particularly comprehensive CPSR dating from before the regulatory changes that took effect in 2013. It covers a wide range of ingredients, additives, permitted colourants and suitable fragrances, giving me considerable flexibility when creating new soap varieties, provided everything remains within the assessment’s conditions and current safety requirements. Not every soapmaker has that flexibility. Some assessments are much more specific, and introducing a new fragrance or changing a formula can mean further assessment work and additional expense.
It’s one of the reasons creating lots of different soaps isn’t necessarily as straightforward as simply buying a new bottle of fragrance and getting creative. Although I do enjoy the getting creative part rather a lot.
Is a CPSR the only requirement?
Oh, if only. 😂
There’s quite a bit more involved in legally selling cosmetic products in the UK. As well as having the relevant safety assessment, I need to maintain product information and manufacturing records, follow appropriate good manufacturing practices and label my products correctly.
I also need to ensure that the necessary product notifications have been made. Here in the UK, cosmetic products which are to be sold to the public must be registered with the Office for Product Safety and Standards – a Government Department – before being placed on the market.
My manufacturing records allow me to identify individual batches of soap, including which ingredients were used and when each batch was made. That’s why you’ll find a batch code on my packaging. It means that if a problem ever arises, I can trace the relevant batch and investigate it. And yes, this all involves rather a lot of paperwork. And my records go right back to my early days, with formal batch records begin in 2012 (before that I have a folder full of copious written notes, created while I was still learning the craft).
I often complain that the washing-up is the worst part of soapmaking, but paperwork is certainly making a determined effort to catch up.
Does a safety assessment guarantee that a product will suit everyone?
No, absolutely not. A product can be correctly formulated, appropriately assessed and legally compliant, and still contain an ingredient that a particular person is allergic or sensitive to.
For example, a fragrance might be perfectly suitable for use in a cosmetic product at its assessed concentration, while still causing a reaction in somebody who has an allergy to one of its components. That’s one reason ingredient labelling is so important. It helps customers identify ingredients they know they need to avoid.
So a CPSR isn’t a promise that absolutely everybody can use a product without any possibility of irritation. It’s a professional safety assessment of the product under its intended and reasonably foreseeable conditions of use.
Why does all this matter?
Because when somebody buys soap from me, they’re trusting that I’ve done considerably more than make something that looks pretty and smells lovely. They’re trusting that I’ve chosen suitable ingredients, calculated my formulations accurately, followed proper manufacturing procedures and complied with the safety requirements that apply to the products I’m selling. That feels like quite a responsibility.
It’s also something worth remembering when comparing the prices of handmade soap. The cost of a bar doesn’t just reflect the oils, butters, fragrance and packaging. There are assessments, record-keeping, equipment, training, compliance and all sorts of other less visible costs involved in running a legitimate cosmetic business.
None of this is particularly glamorous, and it certainly isn’t the reason I fell in love with soapmaking. But it’s an essential part of being able to sell the products I make.
So the next time you unwrap one of my bars, I hope you’ll enjoy the fragrance, admire the swirls and look forward to using it. You don’t need to think about the safety assessment, manufacturing documentation or batch records. That’s my job. And I’m very happy to do it (well, perhaps happy is a bit strong! 😬😝 )
Vicki x