CPSR & The Truth
Updated: Jun 4, 2021
You're starting up a new beard brand within the UK and looking for a bit of advice moving forward. You jump onto YouTube or start talking to "knowledgeable" guys within the bearded community who supposedly know their shit when it comes to beard products. They have tested, reviewed loads, may have thousands of followers or even put guides out talking about CPSR themselves. General advice appears is get your CPSR done and your good to go as no one mentions anything else..... FUCKING WRONG ADVICE!! Simply getting a CPSR will not put you in a position to legally sell because there are more hoops to jump through than a dog at Cruffs before you won't have to worry about potential legal ramifications.
Bad advice populates the internet like maggots on a carcus, to which I have spoke about "Fake Reviews" in a previous blog found here, or if you really want to travel down the rabbit hole then read my " The REAL Beard Struggle of small batch companies and beard clubs" which can be found here. As ever I'm here to shed more light on an area which is shadowed in bullshit, muddier than a pig sty and more misleading than a politicians manifesto.
**Please remember I am no expert however I have bothered to do my research by actually talking to toxicologists, chemists, testing labs and general research through the internet but if I missed anything then please let me know so I can update the guide.**
Here is my first bit of advice before I even start. Talk to actual labs who will guide you through the whole process rather than getting provided with half factual information which was copy and pasted by someone who has no true understanding of the UK market. I have no shadow of a doubt that intentions are pure and only serve to offer guidance however misleading information is damaging, not only to the company but to the UK industry as a whole. No advise is better than piss poor advise, so please do your research before reaching out. Although that seems rather contradictory for me to say as I'm providing advice, I can assure you what I'm offering has been deeply researched by myself however there are people who are plenty more knowledgeable people than me, so I do implore you to seek help from people who know how this stuff works which as a general rule of thumb won't be from a guy sitting on his couch making YouTube videos whilst picking his nose or even from a muppet writing a blog.
Sorry, rant over now let's get to business!
Why Do You Need To Get Your Products Safety Approved?
Surely it's all just a load of rubbish and the UK are just being protective or its a money grabbing scam by the government? You're using great ingredients, keeping to what you think is safe and within the IFRA guidelines. Why should you have to pay out your hard earned Wonga and get it all safety approved?
Well to put this as simplistic as possible.... IT'S THE LAW!
"Regulation (EC) No 1223/2009 on cosmetic products makes it an offence to supply a cosmetic product that may cause damage to human health or contains specific restricted or prohibited substances."
Now if you think your getting a simple slap on the wrist by breaking this law then you seriously have another thing coming. Upon successful conviction of breaking the above regulation you can find yourself being punished by a fine up to but not exceeding £20,000 OR a prison sentence of up to but not exceeding 12 months OR a combination of the two previously stated punishments, which is governed and enforced by your local council.
If your looking at avoiding potentially 12 months of refusing to shower in case you drop the soap then my advice is to get your company on the straight and narrow by conforming to legislation which is outlined in 4 easy steps below.
Step 1 - Get Your CPSR
Congratulations, months of trial and error have led you to make your magic tonic which is going to blow away every competitor out there, even the fake sheep following Vikings. You think you are within the potential legal limit set within the UK which as a general rule of thumb appears to be anywhere between 2-5%. Legal limits will vary depending on the mixture of ingredients you are using but there also appears to be a slight discrepancy between testing labs which can dictate safe measurements. Find yourself a reputable testing lab like Naturally Balmy or The Soap Kitchen to start your nightmare endeavour of getting products approved. Weeks go by with sometimes very limited interaction from the testing lab. The odd message you do get is often something petty which seems inconsequential or you may even need to tweak your formula from the beginning but congratulations they eventually pass your product as safe to be sold within the UK / EU. Although at this point you may have very little hair remaining due to the stress, at least your can say your products are safe.
Ready to sell? Unfortunately your budding entrepreneur enthusiasm will have to hold onto itself a little while longer before your actually allowed to sell anything. CPSR is not the final hurdle and this is where my guide begins to expand on where others fail to.
Step 2 - Create Your Labels
Normally this is probably something which you may of got sorted already and is part of your branding theme however what needs to be on a label? Surprisingly there needs to be LOADS and it's supposed to fit onto such a small little piece of paper wrapped around your bottle or attached label. Not just on the bottle though it should also be listed on your company website / Etsy or any other selling platform. Most good testing labs will offer guidance on this but unfortunately that is not always the case.
Ingredients - That's almost a bit too obvious? Surprisingly not and it's something which I have seen way too often with brands including terms like "carrier oil blend." Its your responsibility to list every ingredient within your bottle which includes carrier, fragrance and essential oils. Ingredients should be listed within a certain order from highest concentration to lowest within a bottle. A blend of 50% Jojoba, 30% Grapeseed, 15% Argan, 3% Sandalwood and 2% Mango, should be listed in that order due to concentration percentage however a selection of ingredients under 1% can go in any order at the end of your list. If you are using a pre-blend fragrance oil like an aftershave inspired cologne then to label "Fragrance Oil Blend" is acceptable.
Continuing on the ingredients section, all ingredients should be labelled within their correct Latin / Scientific name, for example Jojoba is Simmondsia Chinensis. The reason behind this is because common names quite often vary from country to country due to translation errors however the scientific term will never change unless the ingredient is reclassified within a new plant genus. If a product is labelled as being sold within the UK only, and never sold out of the UK then a very grey area does appear to of been found allowing for common names to be used over scientific however my advise would be just to use scientific names to save future problems and costs for correcting labels. This loophole appears only to represent when manufacturing and selling within a single country which I'm sure most company owners won't want to restrict themselves.
Precautions / Allergens - Shockingly something which is missed time after time again. Allergens can quite literally kill someone so this should ALWAYS be on a label with the allergen written in bold. Poor excuses of someone with an allergy would look at the ingredients anyway before purchasing, is something which should never be taken into an assumption. Within this section a precautionary note should also be mentioned with the advise to test on a small section of skin first encase the user has a allergic reaction.
Batch Number - Another feature which is quite often overlooked with small batch brands. When you are making your products you will create a "batch" of perhaps 20 bottles, which you will stock and hopefully sell. You will need to record this batch number within your records and also have it visible on the product. If there was an issue with a product and a recall had to be issued then you would be able to retract every product sold within that batch number. Simple errors can occur like mislabelled supplier products, to dangerous contaminants but no matter what the problem is you can put a statement out to recall any product within that batch number.
Company Address - Whilst this may seem a little daunting for small batch owners to put their home address this is a legal requirement. This will allow the user or authority to trace the company and contact them if unavailable using other methods.
Quantity - Something which once again seems obvious, inserting the product weight or measurement is another legal requirement. Also be very aware of your measurements or weights as underselling the amounts can land you in hot water. This process should especially be taken into consideration when making butters or balms. Just because you have a 100ml jar doesn't always mean your hitting that desired measurement when pouring freehand.
Period After Opening - Virtually all products have use by or best before date with beard products being no exception to this rule. A small symbol or written labelling should make the life expectancy clear for your products once opened especially if it's life expectancy is under 30 months.
Product Name And Function - You will need to put your product name on the label and if considered unclear or not obvious then you will also need to supply the product function for example Docks Bearded Reviews, Mango Madness, Beard Oil.
Intended Country For Distribution - This another thing quite often missed and it's very simple. As a company you must openly display your market and that would be your declaration to ensure you uphold that markets standard. Declaration of "Sold Within The UK Only" or " Sold Within The UK / EU Only" or finally " Sold Worldwide" Will set your target market.
Step 3 - Create Your PIF (Product Information File)
Another step which no one told you about which prompts spasms of thoughts which simply rattle through your brain asking " What the fuck is this?" The PIF (Product Information File) is a document which is kept with the company, outlining everything a responsible authority will need to know about your product, your company and how your running your brand like a Pablo Escobar sherbet shop. The following information needs to be kept within the PIF.
Product Name - Exactly as it says. You will need to show the product names for each item you are selling with an item description for each one.
CPSR - This little beauty pops up again. Don't worry you have this covered and all you need to do is literally copy your whole report into the folder. This will allow the authority to check your product has actually passed its safety testing and aligns up with the products you are selling.
Manufacturing Method Statement - This is basically your risk assessment showing that you are manufacturing in a safe manner and under good practices. Appropriate personal protective equipment, hygienic standards, methods of making and potentially even staff training records to ensure the product you are making can be replicated safely and confidently in a safe /sterile environment. These are rather generic and can be obtained via an external audit or through a Google search to give you examples.
Data On Animal Testing - If you are testing your items on animals then you are going to be in trouble as it's been banned in the EU since 2009. You will need a small statement confirming this is not the case as your are purchasing all your ingredients from approved sellers.
Evidence To Support Your Claims - If you're selling a product under the guidance of beard, skin and follicle nourishment then you will need to supply evidence why its working and that you are not misleading your consumers. Individual evidence for each ingredient from scientific studies will easily fulfil this area however a company study will also be sufficient which explains how derma rollers sneak through through net.
Labelling Information - Go back to step 2 and fill up your file with all your product labels for each individual product you are selling. Just copy and paste that label.
Step 4 - Register on the EU / CPNP or OPSS
Don't worry you are nearly there with this final step to go however this can be a mountain of a task in itself. The CPNP stands for Cosmetic Products Notification Portal and is a central hub for manufactures in order to have their products registered to be sold within the EU market. If you are ONLY selling within the UK then you will need to register on the OPSS which stands for Office for Product Safety and Standards.
To complete your final step you will need to register yourself on these portals, with an external guide linked here. Once registered you will need to supply the following information.
· An image of the product label or packaging
· Details of the company responsible person and address
Well despite all the long nights, triple producing virtually every bit of information and feeling like you've just sold your soul to the devil in the small print of all the paperwork you've collated....YOU'RE READY TO GO! Being pulled on a string of just believing you need a CPSR to sell a product is so far from the truth is almost laughable however doing things right is the most important thing you can do as a company. No one ever said the journey of a beard brand owner was going to be easy however you have started as you have meant to proceed by doing things correctly. The continued journey will be tough as there are many arseholes out there however there is a wonderful community also readily available with many company owners, reviewers, and consumers who are prepared to help you on this journey.
I hope you have enjoyed the guide and please don't hesitate to ask for help if you need it. I am part of an organisation called The UK Beard Portal with aims to help small batch brands grow by offering support. We have a committee which is made up of company owners and reviewers who are prepared to offer you guidance on anything which we can help with. Please check out The UK Beard Portal Website Here or jump onto our Instagram and Facebook.
Stay safe, Stay Bearded and Peace Out.