In our new series of FAQ Friday, we were asked:
Can I manufacture cosmetics in my kitchen?
Yes, you can, however, there are some laws and regulations around this process to stop your products from becoming adulterated, spoiled, or toxic. We’re not covering product making(to be covered in another post) but product production place.
Firstly what is classed as a cosmetic:
A “cosmetic product” shall mean any substance or mixture intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips, and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance and/or correcting body odours and/or protecting them or keeping them in good condition.
Basically, if it touches your skin it could be cosmetic and should be treated so.
How can you be compliant?
On 11 July 2013 the new EU Regulation 1223/2009 – ‘EU Cosmetics Regulation’- came into force stating in Article 8.1 that ‘Manufacturing of cosmetic products shall comply with good manufacturing practice’. Furthermore, article 8.2 states: ‘Compliance with good manufacturing practice shall be presumed where the manufacture is in accordance with the relevant harmonised standards…’
This means that you don’t have to get any specific certification to comply but you are expected to adhere to the guidelines and be able to show as such if you are inspected or investigated. Although not compulsory you are legally obligated to do your best to apply stringent measures to ensure hygiene, precise weighing of products, pH controls, correct documentation, and ensure safe waste disposal. The highest standards are expected and must be implemented for customer safety.
Principle Guideline for Equipment and Premises
Premises and equipment must be located, designed, constructed, adapted, and maintained to suit the operations to be carried out. Their layout and design must aim to minimise the risk of errors and permit effective cleaning and maintenance in order to avoid cross-contamination, build-up of dust or dirt, and, in general, any adverse effect on the quality of products.
Some of the key points are below
- The manufacturing space must present minimal risk of causing contamination of materials or products. It should be well maintained, and its operation should not cause a hazard to the quality of products.
- Premises should be kept clean and disinfected where required.
- Lighting, temperature, and ventilation should be appropriate for the space.
- Are people going to be walking in the kitchen when you’re using it? Steps should be taken from allowing unauthorised people into the space, and the space should not be a right of way for others.
- Do you have adequate storage and production space to prevent mixups? Premises for the packaging of medicinal products should be specifically designed and laid out so as to avoid mix-ups or cross-contamination.
- Quality Control laboratories should be separated from production areas.
- Do you have separate storage and office space away from your maker area? There should be adequate suitable storage space for samples and records away from the production area.
- Rest and refreshment rooms should be separate from other areas. You can not use your kitchen as such when manufacturing in the space.
- Toilets should not directly communicate with production or storage areas. A lot of houses have toilets directly off from kitchens, this could be a source of cross-contamination risks.
- Measuring, weighing, recording, and control equipment should be calibrated and checked at defined intervals by appropriate methods.
- Adequate records of weight tests, cleaning schedules, and production records should be maintained and stored.
These are just some of the regulations set forth in the Good Manufacturing Practice but to be fully compliant you need to adhere to all of them, it doesn’t matter if you are manufacturing from a huge dedicated production area or your kitchen at home, the rules are the same.
When we looked at manufacturing we built a dedicated area to ensure maximum compliance, separating our cleanroom manufacturing space from the storage and office space. If you’re considering making your own cosmetics you should follow all the guidance, or you can save the worry and stress by hiring a company already compliant to manufacture for you.
Essench UK can do the hard work for you leaving you to enjoy building and sales for your brand. Contact us at firstname.lastname@example.org to discuss your cosmetic brand or click here for more information.