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Naturallythinking Pure Aromatherapy and Spa

Cosmetic Product Safety Report, Creating Your Products and Legislation

If you make products which are will sell within the UK and EU, you are legally obliged under the "Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products" to have performed a Cosmetic Product Safety Report (CPSR) on your product. The report should be carried out by a person with the relevant qualifications and experience.

In 2013, these rules get tougher with the onus on the producer to declare their products are being placed on the market, rather than current regulations in the UK that allow for more trust and you will only be inspected if the relevant authority requests your documents in the UK.

These rules affect you now, every product you sell, whether it to be to family and friends, at a market stall, within Spa’s or at a retail outlet or on the internet requires a toxicology report.

Due to the growing needs of our customers and due to our own requirements, we have our own in-house Toxicologist to ensure full legal and product compliance of your products, carrying out the testing (if required) and final Cosmetic Product Safety Report to current regulations.

The 2013 Regulations require that your products are micro-biologically (Preservative Efficacy Test) and Stability tested before the Cosmetic Product Safety Report can be made. We also offer these services at very competitive rates for all of our customer, new or old.

The toxicology report, microbiological testing and stability testing should form part of your “Product Information Pack”. This pack is relatively easy and simple to prepare, although a little time consuming. For customers that feel unsure about their obligations under EU laws, we hold training courses at our headquarters in Croydon. The courses are friendly and full of different abilities from those that have never made products before to industry professionals. More details on our courses can be found by clicking here. Discounts are available on our report and testing services for those that have attended our EU Regulations and GMP courses.

The Information Required to Create Cosmetic Product Safety Report

We do not need to physically see your product in order to create a Safety Assessment, however if you require us to do your microbiological and stability test, then we will need samples of your product (details below). If you have testing data from alternative sources, we can produce your Safety Assessment without you providing samples of your product.

To produce your safety assessment we need to know the ingredients that you are putting into your product and the percentage of each. If you are manufacturing a product from scratch, we need every ingredient (including the MSDS data and if relevant Certificate of Analysis (COA) and Allergens Declaration (for essential oils), if you are using a Naturallythinking base, you just need to tell us the base you are using and the ingredients you are adding.

Example of Information required for a Product formulated from Naturallythinking Ingredients (Lavender and Tea Tree Moisture Cream)

 INGREDIENT

 

SUPPLIED BY

 

Conc.

MOISTURE CREAM

NATURALLYTHINKING

98%

LAVENDER ESSENTIAL OIL (BULGARIAN),LAVENDULA ANGUSTIFOLIA

NATURALLYTHINKING

1%

TEA TREE ESSENTIAL OIL

NATURALLYTHINKING

1%

The above example illustrates the information you will need to provide if you are making a Lavender and Tea Tree Cream using a Naturallythinking moisture cream

We are happy to create toxicology reports for both products built upon our bases and products which are formulated without the use of our products. For all ingredients that aren't purchased from Naturallythinking we will need a copy of the Material Data Safety Sheet (MSDS). You can obtain this from your supplier. Many suppliers this is downloadable from their website, for others they may send them by email to you.

For all formulations, in addition to the product details, we will need your details on Product Name and Registered Address.

What to Expect from Us

Once you submit your data for your Cosmetic Product Safety Report, our toxicologist will initially look over your formula*. The regulations make statements on the maximum percentages of many products as well as their effects when combined with other ingredients, so our toxicologist will look over your formula to examine the cumulative effects of many of your ingredients. Our toxicologist will also look over formula to ensure you are not using any banned ingredients.

If our toxicologist finds any problems with your formulation, she will contact and tell you where your product breaks EU regulations. You should then reformulate your product and resubmit your revised formulation**.

When the basic formulation is created, our toxicologist will prepare your toxicology report. In the toxicology report she will outline the following areas:

  • Toxicological Content, with ingredient toxicology reviews
  • Safety Labeling Advice
  • Product Analysis
  • Labeling Suggestion for Ingredients
  • Toxicological and Regulatory Review
  • Provide a Sign off

As part of the analysis, our toxicology report will also include any specific details about warnings and precautions you should include on your label.

PLEASE NOTE WE CANNOT COMPLETE THE SAFETY ASSESSMENT WITHOUT MICROBIOLOGICAL PRESERVATIVE TESTING and CANNOT MAKE RECOMMENDATIONS ON SHELF LIFE WITHOUT STABILITY TESTING. You can get these performed elsewhere and pass us the testing certificates or we can carry these out for you as part of the overall testing (see options when adding to cart).

Cosmetic Products Safety Assessment (CPSR) Details

MSDS Information  Click here to download our toxicology brochure

Naturallythinking Professional Price £25 click to find out how to join...

£39.00 (inc. VAT)
Product Name:
Product Formulation:
Product Manufacture Address:
Purpose of Product:
Packaging Material:
Closure Material and Liner:
Responsible Person:
Contact Phone Number:
Contact Email Address:
Upload Details (optional):

(Maximum Size: 4.88 MB. Type: gif,jpg,doc,docx,xls,odt,ods,pdf,txt)

The information we need from you

Your Product Details

Bulk and Wholesale

Tell us more about your product

Product Name, Formulation (INCI), Manufacture Address, Purpose of the Product, Packaging Material include closure, the Responsible Person, Contact Phone Number and Email address.

For each ingredient you use, we will need to send the MSDS (Material Safety Data Sheet), COA (Certificate of Analysis) & Allergens Declaration for Essential Oils, unless the ingredient / component is purchased from Naturallythinking, in which case we will have this information on file.

We will also require the specification of your packaging, from your packaging supplier, once again if this is supplied by Naturallythinking, just let us know and we will complete the information.

Your Stability Test Data

Naturallythinking Packaging

We need to determine the shelf life

The CPSR should include full details of the shelf life of your product, which should be derived from stability data. If you have been previously selling the product, we can use historical data i.e. you can make a declaration to say your product doesn't change composition in 12 months, then we can award your product a 12 month shelf life. If you do not have this data, then you will need to perform stability tests. We can do these tests for you, please click here for more details.

Your Preservative Efficacy Test Data

Refill and Trial

Bacteria free products

The CPSR should include details about the efficacy of the preservative system in your product. If your product is 100% oil based and includes no water (including ingredients that contain water), then you will not need this test as bacteria does not grow in water. If your product does contain water, you will need this test to determine how well the preservative system in your product works. We can do these tests for you, please click here for more details. If you want to know more about preservatives, we offer a morning course, to help you choose the best preservatives for your products.

Place your order

Bulk and Wholesale

Order online and if applicable post your samples

Ordering your CPSR is simple, by filling in the details on this page and if required, posting your samples for Preservative and Stability testing to

Maria Mayordomo
Naturallythinking
Toxicology & Regulatory
The Tramsheds, Coomber Way
Croydon, Surrey, CR0 4TQ

Please ensure your order number is included in the package.

Please note we will not start your CPSR until we have received all of your information (MSDS, COA, Allergens Declaration (as applicable)). If you are purchasing the ingredients from Naturallythinking, please just send us an email to let us know (toxicology@naturallythinking.eu), so we will commence your report

How long will it take to receive your CPSR?

If your product needs testing

If your product requires Preservative and / or Stability Testing we will not be able to complete the CPSR until this testing is completed as it forms a vital part of the Cosmetic Product Safety Report. The minimum time we could complete your CPSR is 9 weeks if you require testing.

If your product does not need testing.

If you already have testing data or your product meets the criteria that it doesn't need preservative or stability testing, then we aim to complete your CPSR within 28 days of receiving all of the information.

Do you have to buy all your ingredients from Naturallythinking

No, we are happy to produce assessments for products made with Naturallythinking ingredients and those from other companies.

Is there a maximum number of ingredients

We have a fair usage policy, which sets the maximum number of ingredients at 20 for our fixed price of £39. If you have more ingredients in your product than 20, please email us for a quote.

Common Questions on CPSR's

Do I need a separate CPSR for each product?

Yes

Under the old regulations it was ambiguous as to whether you could cover many formulations with one CPSR. With the new regulations, each product needs it's own Cosmetic Product Safety Report. We do not offer any discounts for multiple CPSR's as we already offer a highly competitive price.

Discounts are available to Naturallythinking Professional members, please click here for more details

I am a small producer, does this apply to me?

Yes

If you produce one, or one million products per year, if you place your product on the market for sale, you will need a Cosmetic Product Safety Report for your product. The regulations take no account of size of business, they focus on the safety of the product.

I am simply re-branding a product, does this apply to me?

Yes

The regulations state that, simply re-branding the product will require a new Cosmetic Product Safety Report to be created. If you are re-branding a Naturallythinking product, we will shortly be launching a reduced price CPSR service for these products.

I am unsure of my obligations under EU law

We have a training course just for you

Our experienced teachers will teach you your obligations under EU law in a 2 day course, held at our headquarters in Croydon, Surrey. In addition if you also attend our Good Manufacturing course, you can receive substantial testing and CPSR prices. Click here for more details.

Validity of our Safety Assessments

Fully to EU Regulations

Our Cosmetic Product Safety Reports (CPSR) are fully compliant with current EU Regulations, specifically "Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products". We operate a very strict interpretation of the regulations, to ensure full compliance.

Valid in all EU Countries

Our Cosmetic Product Safety Reports are valid in all EU member states (Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom).

Our reports are written in English and whilst this is valid for most EU countries, you will need to check any country specific legislation that may require you to have the report written in your country's language.

About our Toxicologist

Our toxicologist, Maria Mayordomo is a registered Pharmacist in the UK (MPharm) with a masters in Pharmacy and a degree in Sports Nutrition.

Maria actively works on Cosmetic formulation, looking at new and innovative ingredients and their effective implementation into cosmetic function. Maria heads our laboratory and is responsible for all Microbiological preservative and stability testing.

Maria has recently spent a week at the EU in Brussels with those that legislate and create the law to ensure our full compliance and understanding of the law.

Why are our prices so much lower?

As a producer of cosmetic products, cosmetics are our business. We use the excess capacity of our in-house laboratory and custom software solutions to be able to offer these low prices to our customers. Our reports are more detailed and in-depth than most assessors and we are very strict on criteria to ensure our high standards are met.

Terms & Conditions of Cosmetic Product Safety Report Submission

Advice

Our CPSR service is not an advisory service, we will not advise on your submitted formulation, we will test your formulation against EU parameters and advise you if you exceed parameters, however it is your responsibility to reformulate your product to meet EU guidelines. If you need any help or advice to do this, we offer EU training courses and a 1 to 1 advice service separately. If you need to reformulate, there will be a £10 administration charge to look at your new submitted formula and check ingredients are within EU guidelines.

Refunds

*By agreeing to our terms and conditions when placing your order, you are agreeing that this is a customised service and therefore your order cannot be canceled. On placing your order, your CPSR work will commence immediately and full production will be scheduled into our schedule. **If you need to reformulate, there will be a £10 administration charge to check your new submitted formula and ensure ingredients are within EU guidelines.

Return of Product

When your testing is complete, we cannot return the tested products, whether they fail or pass.

The bacteria which are injected into your products are to be handled by a Class II laboratory and as such, we are responsible to ensure the waste is disposed of using a waste company with the correct facilities to handle medical waste.

Failed Testing

If your testing fails, you will need to submit a new batch of product for testing. Your testing fee includes only one test, so you will need to pay again your testing fee.

If you also have a CPSR (Cosmetic Product Safety Report), being produced, we will not be able to sign off your CPSR until the testing successfully passes.

The information provided by Naturallythinking on our website and via other social media channels is for personal information and interest only. It is not intended to offer professional medical advice or treatment for any condition. You should not use our site or advice within to treat health conditions or to self-diagnose... Click here for full information

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