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Naturallythinking Pure Aromatherapy and Spa

Cosmetic Product Safety Report (CPSR), Producing your Products and EU Legislation

If you make products to be sold within the UK and EU, you are legally obliged under "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.

The EU legislation rules apply to all, regardless of your size and your intended audience, so whether you sell to family and friends, at a market stall, within Spa’s or at a retail outlet or on the internet, you require a CPSR.

Due to the growing needs of our customers and our own requirements, we have our own in-house Toxicologist and Laboratory to ensure full legal and product compliance of cosmetic products. For many product CPSR is the only requirement, but if you require additional testing then we can also perform this for you in-house to produce your final Cosmetic Product Safety Report (CPSR).

The Information in the Cosmetic Product Safety Report (CPSR)

We compile Cosmetic Product Safety Reports as per EU requirements. As per the regulations there is a Part A (Cosmetic Product Safety Information) and Part B (Cosmetic Product Safety Assessment). Part A, the Cosmetic Product Safety Information explores each ingredient, looking at the safety evidence from various sources and relevant data for the ingredient. Part B, the Cosmetic Product Safety Assessment, is produced by our in-house Toxicologist (Sonia Garcia), who meets and exceeds the requirements of a suitably qualified person to perform the Safety assessment as defined by EU Regulation (EC) 1223/2009.

Exactly what testing do you need?

If your product contains water the 2013 Regulations require that your products have micro-biological (Preservative Efficacy Test) performed on them. In addition the CPSR must make mention of the expiry date / shelf life of your product and there, if you have no historical data a Stability test should be performed before the Cosmetic Product Safety Report can be completed. If you require a PET test (click here) or Stability test (click here). The individual testing pages explain in more detail whether you will need the test(s).

The Cosmetic Product Safety Report (CPSR), Microbiological Testing (PET) 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 training center 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 (PET) and Stability Testing, then we will need samples of your product (see the individual testing pages for more details). 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.

The following is an example of the information we would need for a product which you have formulated from an individual ingredients


 INGREDIENT

 

SUPPLIED BY

 

Conc.

Moisture Cream Base

Naturallythinking

98%

Lavendula angustifolia (Lavender) Essential Oil

Naturallythinking

1%

Melaleuca alternifolia (Tea Tree) Essential Oil Naturallythinking 0.8%

Tocopheryl acetate (Vitamin E)

Naturallythinking

0.2%

The following is an example of the information we would need for a product which is made from a Naturallythinking base


 INGREDIENT

 

SUPPLIED BY

 

Conc.

Cetearyl alcohol

Naturallythinking

1%

Cetyl alcohol Naturallythinking 1%
Glycerin Naturallythinking 1%
Stearic acid Naturallythinking 0.8%

Lavendula angustifolia (Lavender) Essential Oil

Naturallythinking

1%

Melaleuca alternifolia (Tea Tree) Essential Oil Naturallythinking 0.8%

Tocopheryl acetate (Vitamin E)

Naturallythinking

0.2%


Do you have to buy all the ingredients from Naturallythinking?

No, 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. For many suppliers this is downloadable from their website, for others they may send them by email to you.

The additional Legal Information we require

All formulations require the following information to be legal:

The Product Name (This is the name you give the product)
The Responsible Person (This can be your name or the name of your company. EU law stipulates the person / company must be within the EU)
Responsible Person Contact Details (Telephone and Email contacts)
The Registered Address (EU law stipulates the registered address must be within the EU. This can be a home or work address)

Additional Information we need

In order to assess the safety of your product, we need to know

The intended use of your product, for example Shower gel, Moisture Cream

What to Expect from Us

Once you submit your product for a CPSR, and agree to the Terms and Conditions of placing your order, we cannot cancel or change your order. Our toxicologist will start the assessment of your product and aim to complete your CPSR within 28 days of receiving all of your information and if relevant the conclusion of your PET and Stability Testing.

If your product fails EU requirements

If your product fails the legal requirements of the CPSR, we will inform you that your product has failed the CPSR. We will tell you the area(s) that your product has failed, however we are unable to re-formulate for you. If your product fails and you have to reformulate, this potentially could invalidate your Stability and PET testing, so if you have any doubts as to whether your product will pass EU legal requirements, please use our Pre-Assessment service (details below) to save yourself the expense of having to resubmit everything for testing in the event of a failure.

If your product passes EU requirements

We will issue you your Cosmetic Product Safety Report (CPSR), by email with a digitally encrypted PDF.

You can now notify your product on the EU portal and start selling your product, there are no additional charges or hidden costs. In order to comply with EU law, you will need to keep records of all your label designs, ingredient and final product batches and any complaints you may receive about your product. This is done by compiling a "Product Information Pack", which you can do at home. If you want to learn more about compiling your product information pack and your obligations under EU law, we run regular courses in Croydon, England. Full details can be found by clicking here.

Apply for a Pre-Assessment

This isn't required, but could save you a lot of money if you are unsure whether your product meets the requirements of EU law.

Place your order following the instructions above, but choose "Pre-Assessment" from the drop down. We will assess your formula within 7 working days of placing your order. We will assess whether the formula meets legal requirements of the EU. If it does, we will inform you. You can then place your full order for a CPSR and testing if required, without the worry that the formula fails and therefore invalidates all of your testing results.

A per-assessment isn't a guarantee that your product will pass Stability Testing or Preservative Efficacy Testing, it checks that all your ingredients, combinations of ingredients and internal components of the ingredients are within limits imposed by the EU regulations.

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)
Type of Report:

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

Sonia Garcia
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 working 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, Dr Sonia Garcia has a BSc Biolgy from the University of Basque Country and an MS Pharmacology, Industria Drug Development (University of Basque Country). Dr Garcia completed her PhD at the University of Reading in Toxicology and has an MS in Teaching.

How 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.

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.

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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