Can I sell, donate or give away my handmade soap and skincare products?
The million dollar question and one which crops up frequently. Can you sell your soap and other skincare products to make a bit of extra money, or indeed, start a whole new business and ditch the day job?
Here in the UK the answer is yes, but only once you have jumped through an awful lot of hoops to comply with relevant legislation, and rightly so, after all - we are looking at products that are applied directly to the skin, the largest organ we possess. If you want to jump straight into the legislation then you can find it here but like most gov.uk websites it is a little wordy so read on if you would like the short version.
It is a large and somewhat complex subject so this is not a 'how to'. It is however an introduction into what is involved so that you can make an informed decision about whether you want to be taking things further, particularly in the current economic climate where, lets be honest, life is pretty tough for small business owners.
As a guide, before you can sell or donate your soap and other products to anyone (other than gift it to close family and friends for their personal use) you need to do the following.
Create your recipes and get them assessed by a cosmetic chemist. This has changed a lot in recent years. At one stage you would spend many months making test batches and perfecting your finished product but these days there are various chemists out there who offer 'pre-assessed' assessments and in an eye watering variety of products. These often have the option to personalise some of the ingredients so you can still make them your own.
If that is not for you then custom assessments are still very much a 'thing' too and generally you can have 1 base recipe with up to 12 variations (scent, colour, additives etc) and that will cost you upwards of £125 to £300 depending on how many options you need. Prices do vary considerable so shop around and be aware that each type of product will count as 1 base recipe so if you are hoping to make and sell soap, lip balm, body butter etc each one of those will need it's own custom assessment. As you can see the cost can start racking up very quickly. Once complete this means your recipes have been declared as safe and compliant to UK (and generally EU) specifications.
After obtaining those papers you need to register yourself as the Responsible Person and your products on the UK Cosmetic Products Portal - there are now different ones for the UK and EU so which one you use depends on where you are selling your products. If you are in the UK and want to sell in the EU you will need to upload your products to the EU portal too PLUS have a Responsible Person located in the EU.
You will be pleased to hear that accessing and uploading products to the portal is free. Learning how to use it is the hardest bit and even that really is not too much of a challenge. If you would like to see how the portal works I have a You Tube video here. They do tweak things from time to time so it may not be exactly how it is now but it will give you an idea.
You need to keep Product Information Files (PIF) which are in effect, files recording every detail about your soap manufacturing.
Your PIF is not one document, it consists of multiple documents covering everything from your cosmetic assessments to records about how you make your products right through to documentation about the raw materials you are using ie MSDS sheets, certificates of analysis, IFRA documentation and the records you keep of all the products you make with batch numbers, pretty much everything and anything you can think of relating to the manufacture of your products and to create an audit trail should things go wrong. You are required to keep all this information for at least 10 years after the last product is manufactured. The PIF often causes confusion, it sounds like it should be one document and all kept in one place but that is not the case, it can be multiple folders in multiple places and either in paper form or online. The important thing is that you know where you can find anything if asked.
You need to keep a record detailing your Good Manufacturing Practice (GMP), ie detail where you will make your products, where and how raw materials and packaging will be stored, stock rotation, use of suitable equipment, waste disposal, how you ensure your finished product is of the correct weight and quality. This sounds like a very formal document but is probably the easiest part of compliance.
You are obliged to include specific information on your labels, these cover ingredients, allergens, weight, address of manufacturer and also abide by weights and measures legislation.
And finally, insurance. You will need product and public liability insurance at the very least. This is not too costly if you use one of the craft insurers.
How will anyone know I am not jumping through all these hoops I hear you ask? Rest assured, Trading Standards can (and do) check. Plus should you have a problem and need to claim on your insurance it will become apparent very quickly, you may be asked to produce documents that you just don't have, and then your insurance will be invalid.
This is very much a whistle stop tour of what is needed and my aim is not to put you off the process, far from it. Everything here is very doable and is just administration but as they say, fore-warned is fore-armed. I think it is fair to say however that the administration far outweighs the making some weeks and it can be a little over whelming.
I hope that has answered some questions for you, it is a large and complex subject and there is far more to it than just this (soap made to look like food is not allowed for example) but it gives you a taste of what you may be letting yourself in for. It may also explain why handmade products cost significantly more than something mass produced for the supermarket !
Inspired? And thinking of stepping your soap making up a level and starting your own business but have no idea where to start? There is a whole lot more to starting a business than just the legislation so why not grab my Soap & Skincare Business Start Up Checklist for a comprehensive list of what is needed to get going and set your business up for success.
Hi Vivienne, the regs are the same whether you are looking at cold process or melt and pour so lots of hoops to jump through I am afraid
Hi, if I buy the pour and melt as I want to make soap to sell with my resin soap dishes, what do I have to do to be able to do that? Many thanks
Hi Alison, no you are fine to gift your soaps to your close friends and family. As far as the regs go beyond that, it is the same for M & P or made from scratch, I hope that helps. Keri
Hi,
What happens if I just make soap for family and friends n close friends but give them as a free sample or gift. Do I still have to down the line on the legal side n the different things aswell. I keep a list of who I send it to what colour, fragrance, style n shape of soap. And give as a sample/gift. And its the melt & pour soap base is it different cos its classed as fake soap.. Where do I stand on this? As I love making them for my friends to try.. Thank u.. 🙂
Hi Dazy, it depends which country you are in, if you are in the UK there are a few options, drop me an email and I will give you some suggestions. Keri
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